Ad description
A paid-for search ad for top10onlinecasinoreviews.co.uk, seen on 18 June, following a search for “help with gambling”. Text stated, “UK’s Top 10 Casino Sites – 10 Best Casino Online Sites UK […] Compare The Best Online Slots Sites In The UK 2026. Fast Signups & Mega Bonuses To Claim. The Only Casino List Compiled Of Real Users Ratings! Signup & Enjoy Our Brilliant Offers”.
Issue
The complainant challenged whether the ad was irresponsibly targeted.
Response
Smart Gravity Ltd t/a top10onlinecasinoreviews.co.uk said they were an affiliate comparison website, and did not operate gambling services themselves. Their website provided comparison content, reviews, and information relating to operators licensed by the UK Gambling Commission.
Smart Gravity understood the ad had been served by Microsoft Advertising. Upon receipt of the complaint, they initiated an internal investigation to understand how the ad was served, including reviewing their campaign settings, keyword targeting, search-term data, and compliance procedures to determine whether any additional safeguards were appropriate. They said their campaigns were configured to target adult users in the UK, using the targeting controls available within the advertising platform. They maintained an ongoing compliance framework to minimise the likelihood that their ads would appear alongside inappropriate search queries, which included periodic reviews of campaign settings and targeting, continuous review of negative keyword exclusions, and internal compliance monitoring. They highlighted that they had no commercial interest in advertising to individuals seeking support for gambling-related harm, and did not intentionally target vulnerable consumers, underage users, or individuals seeking gambling support or self-exclusion services. Their intended audience consisted of adults seeking information regarding licensed gambling operators. They provided their negative keyword list, which was designed to exclude their ads from appearing in results for searches relating to gambling addiction, safer gambling, and topics related to gambling harm. They said that whilst automated systems could not guarantee that every possible keyword match would be prevented, they continuously reviewed their controls to reduce that risk as far as practicable.
Smart Gravity said their advertising strategy used a combination of Exact Match, Phrase Match, and Broad Match keywords. They had not identified any search queries containing the phrase “help with gambling” that had been matched to the keywords they used. They provided two screenshots of Search Term Reports from their Microsoft Advertising account, which provided information about what search terms and wording had been used by consumers when Smart Gravity’s ads had been displayed.
Assessment
Upheld
The ASA considered that by searching for the phrase “help with gambling”, a consumer was likely to be seeking information, advice and support about gambling-related harms. Such consumers were likely to include vulnerable persons looking to manage or reduce their exposure to and engagement with gambling ads. In that context, we considered an ad promoting online casino sites with “Fast Signups” and “Mega Bonuses” was not appropriate to appear in response to that search.
We understood that Smart Gravity Ltd operated an affiliate comparison website rather than a gambling service itself. However, the ad had the effect of promoting online casino and gambling sites. We noted that the Code required that ads for gambling should have particular regard to the need to protect vulnerable persons from being harmed or exploited. We expected that, because of the potential for considerable harm to vulnerable consumers, marketers who placed ads for gambling-related services should have very robust controls in place to prevent their ads from being inappropriately targeted.
We acknowledged that Smart Gravity Ltd operated a negative keyword list intended to exclude their ads from appearing in response to searches related to gambling addiction, safer gambling and gambling harm. However, we understood that they used a mix of broader keyword matching options, some of which meant their ads could be displayed when a consumer searched for terms which related to, but did not contain, keywords that were targeted by the advertiser. We considered that the use of broader keyword-matching options meant there was a risk that the ad would be served in response to searches indicating that a consumer might be experiencing gambling-related harm.
In those circumstances, the advertiser’s negative keyword list and targeting controls had not provided a sufficiently robust safeguard against the ad being shown to potentially vulnerable consumers. Because we considered that there was a strong likelihood that vulnerable consumers seeking to reduce their exposure to and engagement with gambling ads and websites had been served an ad promoting casino websites following a search for “help with gambling”, we concluded that the ad had not been responsibly targeted.
The ad breached CAP Code (Edition 12) rule 1.3 (Social responsibility).
Action
The ad must not be served following the search “help with gambling” again. We told Smart Gravity Ltd t/a top10onlinecasinoreviews.co.uk to ensure that their search ads were responsibly targeted.
