Ad description
An in-app ad for the mobile app casino game “Wolf Gold”, seen in the “Lucky Night” app on 5 May 2022. The ad included images of a prize wheel with a wolf’s face and two women at the top of the page. Accompanying text stated, “Everyone wants to solve theirs [sic] financial problems … Click the ‘DOWNLOAD’ button right now and start to earn … In fact, it’s all very easy to do with our application … pay off loans, buy a car and a nice house … and make a lot of money!” Text beneath this stated “WELCOME BONUS £400”.
Issue
The complainant challenged whether the ad was irresponsible for suggesting that gambling could provide a solution to financial concerns and provide financial security.Response
Rank Digital Gaming (Alderney) Ltd (Rank) said that the ad had been prepared by an affiliate organisation, WakeApp, which purchased in-app media on their behalf. Rank said that they had not been involved in the production or publication of the ad, and had not been aware of it until it had been brought to their attention by the complaint. Rank said that they would not have approved content such as that seen in the ad, if they had been aware of it.
Rank told the ASA that they had raised the matter with WakeApp, and made it clear that the nature of the content was unacceptable, and in contravention of their own internal policies regarding advertising. They said that their terms and conditions for affiliates only permitted the use of copy provided by Rank, or copy created by an affiliate which Rank then directly approved, and that WakeApp had not adhered to that process when creating the ad. Rank said that since being made aware of the ad, they had terminated their working relationship with WakeApp.
Rank also said that the bonus offer included in the ad would not have actually worked, since their app only allowed for the redemption of a default welcome bonus, unrelated to, and much lower than, the figures stated in the ad, which they considered meant the ad was damaging to their brand. They said that they had monitoring tools in place for ads that appeared on web and mobile platforms, but did not, at the time of the complaint, have the same tools in place for in-app advertising. Rank said that they planned to implement such monitoring tools as soon as possible, and did not intend to resume in-app advertising until such tools were in place.
WakeApp told us that the ad did not align with their own internal policies, and accepted that it contravened the CAP Code, but did not offer a substantive explanation for the process behind its creation or publication.
Assessment
Upheld
The ASA welcomed Rank’s assurances that they had taken steps to ensure similar ads would not appear again in the future.
The CAP Code stated that ads for gambling products must not encourage socially irresponsible gambling, or suggest that gambling could be a solution to: financial concerns; an alternative to employment; or a way to achieve financial security.
We considered that the claims “start to earn ... and make a lot of money” suggested to consumers that the gambling product being offered by the advertiser could be used to “earn” money, and therefore attain a regular source of income. We considered this had the effect of suggesting that gambling could be a way to achieve financial security. We also considered the claims that, by using the product consumers would be able pay off loans and afford expensive items, such as cars and houses, clearly suggested that gambling was a way to achieve financial security.
Because the ad suggested that gambling was a way to solve financial concerns and achieve financial security, we therefore concluded it was socially irresponsible.
The ad breached CAP Code (Edition 12) rules 16.1 16.1 Marketing communications for gambling must be socially responsible, with particular regard to the need to protect children, young persons and other vulnerable persons from being harmed or exploited. 16.3 16.3 Marketing communications must not: 16.3.1 16.3.1 portray, condone or encourage gambling behaviour that is socially irresponsible or could lead to financial, social or emotional harm and 16.3.4 16.3.4 suggest that gambling can be a solution to financial concerns, an alternative to employment or a way to achieve financial security (Gambling)
Action
The ad must not appear again in its current form. We told Rank Digital Gaming (Alderney) Ltd to ensure that their future ads, including those prepared by affiliates, did not suggest that gambling was a way to achieve financial security.
