The Advertising Standards Authority (ASA) has penalised three organisations for a combination of advertisements that had an inappropriate appeal to children and which encouraged irresponsible gambling.
First under question is William Hill Vegas, which saw an advert appear within the app New MarioKart 8 Trick, accompanied by the text “William Hill Vegas … All Online Vegas Games 200% Up To £200 Bonus William Hill Vegas” and an install button.
One complainant challenged “whether the ad was appropriately targeted as it was seen while using an app ‘New MarioKart 8 Trick’ which they believed was aimed at children”.
Responding, the firm first pointed to its usage of the Universal App Campaign product from Google, which results in Google automatically serving the ad across its portfolio of inventory – which were limited to serve only individuals who specified their ages as 18+.
Furthemore, WHG International, trading as William Hill Vegas, stated it couldn’t affect sharing of devices between adults and children, and that last year Nintendo Switch reported 86 per cent of its players were adults, and that Mario Kart was one of its most popular titles.
Considering its judgement, the ASA highlights PEGI rating of three for New MarioKart 8 Trick, in addition to stating William Hill Vegas should’ve used some additional interest based factors to reduce the likelihood of under-18s seeing the ad.
Concluding that the ad had been inappropriately targeted, the ASA states that “the ad must not be used again without further, specific targeting to minimise the likelihood of under-18s being exposed to it.
“We told William Hill Vegas to ensure that their ads were appropriately targeted in future.”
A similar complaint was also levelled at Greentube Alderney Ltd, trading as Bell Fruit Casino, with one individual complaining that an advert for its gambling app was seen by their seven year old son in the Dude Perfect 2 app.
Greentube Alderney also pointed its usage of the Google network and the Universal App Campaign product, whilst also stating that following their own internal investigation “they believed that they had taken all steps to ensure that their ads were strictly served to users over the age of 18”.
Miniclip SA, publishers of Dude Perfect 2, detailed that whilst gambling content was prohibited, at the time they had selected the option to disable gambling content.
Before going on to state that “the most popular age demographics for the game were 35- to 54-year-olds on iOS and 25- to 34-year-olds on Android,” and providing age demographics for users who had downloaded the app.
Considering the evidence, the ASA published a lengthy assessment, amongst which it highlighted that “2.5% of users who downloaded the app using their own account were aged 13 to 17. As it was common for children to access apps on shared devices, as was the case in this instance, we considered the actual under-18 audience was likely to be greater than that”.
Adding: “we noted that there were other campaign options on Google AdWords that allowed advertisers to target their campaigns to users based on interest and other behavioural factors”.
Upholding the complaint “the ad must not be used again without further, specific targeting to minimise the likelihood of under-18s being exposed to it,” with Greentube Alderney Ltd reminded to ensure that their ads were appropriately targeted in future.
Finally, one complainant challenged whether text and language used in ad advert for gambling operator Quiff, “portrayed, condoned or encouraged gambling behaviour that was socially irresponsible or could lead to financial, social or emotional harm”.
Responding, Eaton Gate Gaming, trading as Kwiff, said “the ad was intended to show how real customers felt and experienced the app and it did not present gambling in any way that could be considered irresponsible”.
Before going on to state that “the selected customers were first asked questions about themselves, and then questions about their experience in using the app, and their response to those questions were filmed,” with Kwiff insistent that customers had not been coached and the testimonials were not scripted.
Upholding the complaint, the ASA noted that “each of the customers featured in the ad were men and that some appeared to be in their late 20s or early 30s. We understood that younger men (aged 18–34) were at heightened risk of irresponsible gambling behaviour, and we considered that ads which appealed to that audience … needed to take particular care in their messaging”.
Adding “We considered that the overall impression of the ad condoned and encouraged betting in ways that could be financially, socially and emotionally harmful, by associating it with problem gambling, and we concluded that the ad was irresponsible”.
The ad must not appear again in the form, with Kwiff told to ensure in future that they did not condone or encourage betting in ways that could be financially, socially or emotionally harmful.