Ad description
Two web display ads for gambling sites and a webpage seen on www.hltv.org, a website for Counter-Strike 2 eSport content, seen on 27 March 2026.
a. The first ad, for Casimba, featured the text “100% MATCH BONUS UP TO £100 ON 1ST DEPOSIT”. The ad featured the Union Flag, an 18+ logo, and a button with the text “REGISTER NOW”.
b. The second ad, for The Grand Ivy Casino, featured the text “EXCLUSIVE UK WELCOME OFFER REGISTER NOW. 100% MATCH BONUS UP TO £100 ON 1ST DEPOSIT”.
c. The third ad, a webpage for a live Counter Strike 2 match, featured information on the match, including photos of the players, the teams competing, and their stats. Below the heading “Betting”, betting odds were displayed for the two teams playing, alongside the logos for different gambling sites, each with clickable links. The Casimba logo linked to www.casimba.com.
Issue
The complainant challenged whether the ads were appropriately targeted.
Response
White Hat Gaming Ltd t/a Casimba and The Grand Ivy Casino said they did not believe the ads breached the CAP Code. They suspended display of the ads during the investigation.
White Hat Gaming said HLTV was a specialist platform for professional Counter-Strike 2 coverage. They said the site was aimed at adults interested in the strategic and competitive side of the game.
They said audience data for HLTV’s social media accounts demonstrated that HLTV’s audience was overwhelmingly adult. They also provided their own referral data which showed users who registered after coming from HLTV were all adults, with the majority over the age of 25. They therefore believed the ads had been appropriately targeted.
HLTV said they were a specialist, professional e-sports media platform aimed at an adult audience. They said the site focused on professional Counter-Strike 2 coverage, including statistics, match analysis, tournament coverage and industry reporting. They said its content was analytical and data-driven, and did not include features designed to appeal to children. They believed the technical nature of the site attracted a mature audience and was unlikely to appeal to minors seeking casual gameplay.
They said they had received no direct complaints from users about the ads or other advertising on the website.
Assessment
Not upheld
The CAP Code required that marketing communications for gambling must not be directed at those below 18 years of age through the selection of media or context in which they appeared. No medium should be used if more than 25% of its audience was under the age of 18 years.
We considered the context in which the ads were seen and whether the ads were placed in and around content which was obviously directed at under-18s. The ads appeared on a live Counter-Strike 2 match page on HLTV.org. The complainant was not logged in when they saw the ad and their age had not been verified. We understood that Counter-Strike 2 was a multiplayer tactical first-person shooter video game in which teams competed in objective-based rounds. We understood that the game formed part of an established professional e-sports scene. The page featured live coverage of the match, alongside information including player photographs, the teams competing, statistics and betting odds. We acknowledged that the ability to watch the match live on the page could increase the page’s appeal to under-18s, however, the page was framed around coverage of a professional competitive match, and included information likely to be used by those following the event. We therefore considered that the themes and presentation of the page were not aimed at children or young people to the extent that the ads were directed at under-18s by appearing there.
We also considered the audience information supplied by White Hat Gaming and HLTV. We considered that the referral data provided by White Hat Gaming Ltd did not establish the audience of the ad, as any successful referrals would have come only from consumers aged 18 or over. Social media data showed that 1.5% of HLTV’s Instagram audience were aged 13 to 17, and 3.6% of HLTV’s Twitter interactions were from users aged 13 to 17. The social media data did not relate directly to visitors to the HLTV website and we therefore did not consider that it established the age profile of the audience for the website. We understood that the website analytics used by HLTV did not include data for under-18s. While reliable audience data was not available, we considered the likely audience composition, taking into account the content and context in which the ads appeared. For the reasons set out above, we considered the themes and presentation of the webpage were not directed at under-18s, and there was nothing to indicate that under-18s were likely to make up more than 25% of the audience. We noted that the social media data, while not directly representative of website visitors, was consistent with that view.
We therefore concluded that the ads had not been directed at under-18s through the selection of media or context in which it appeared.
We investigated the ads under CAP Code (Edition 12) rules 16.1, and 16.3.13 (Gambling), but did not find them in breach.
Action
No further action necessary.
