ASA Adjudication on Profitable Play Ltd
Profitable Play Ltd
2.2 Waterport Place
31 October 2012
Internet (social networking)
Number of complaints:
A Facebook page for an online bingo game was headed "Bingo Friendzy ... World's First Real Cash Games on Facebook". A number of posts further down the page featured claims such as "Invite Friends & WIN MORE!", "BIG PRIZE GAMES 6pm-10pm every night on Bingo #Friendzy", "Even more chances of winning with Bingo Friendzy's Extra Ball Calls!", "Join the Friendzy!" and "Visit the Candy Cave! Exclusive 90 ball bingo from Bingo #Friendzy". The heading of the page and each post included images of furry cartoon characters.
Two complainants challenged whether the ad was irresponsible because it was likely to be of particular appeal to children.
CAP Code (Edition 12)
Profitable Play Ltd (PP) said they never targeted advertising at under 18-year-olds and that their target audience was the 35–45 age group. They said consumers wanted games to be fun and engaging and that that desire did not stop as people got older. They told us that both the game itself and any advertising were subject to age-gating, which meant that Facebook blocked the fan pages, all friend posts and the application itself from being visible to those under the age of 18. They explained that, before being permitted to play, users were subject to strict account acceptance controls to verify their identity, that they were located in the UK and that they were over 18 years old. If their identity and age could not be verified against independent KYC databases then they would not be able to use the application unless official personal identification, such as a passport, was subsequently provided.
The ASA acknowledged the complainants' concern that the ad was particularly likely to appeal to children and we considered that the imagery used in the ad meant that that was likely to be the case, if children were exposed to it. However, we noted the ad was accessed only via the advertiser's Facebook page, and that access to that page was age-restricted to website users who were 18 or over. We considered that PP had taken reasonable steps to prevent those who were under 18 from viewing the ad and concluded that it did not breach the Code.
We investigated the ad under CAP Code (Edition 12) rules 1.3 (Social responsibility) and 16.1 and 16.3.12 (Gambling) but did not find it in breach.
No further action necessary.