Buzz Bingo rapped by ASA over Halloween marketing
A single complaint was filed to the ASA over the Buzz Bingo ad that appeared on Facebook in October 2023. Buzz Bingo published the advert on its Facebook page.
The ad comprised animated footage of a full moon above a scene featuring pumpkin heads, a church with towers whose roofs resembled witches’ hats, bats flying, a spider in a web and a graveyard with a tombstone and a cross. In addition, text in a font resembling slime read “Monster Mondays – £50,000 must be won every Monday in October”.
The complaint alleged the cartoon Halloween imagery was likely to appeal to children and challenged whether it breached advertising rules.
Responding to the complaint, Buzz Bingo defended the advert. It said the ad appeared on its Facebook page that is restricted to Facebook users aged 18 years and above. It also said the ad was part of a campaign targeted at users aged over 25 with an interest in bingo.
Buzz Bingo said these steps meant it took precautions to prevent children and young people being exposed to the ad. However, it also acknowledged concerns the Halloween imagery could appeal to children and as such removed the advert and made changes to its internal marketing approval procedures.
ASA: Buzz Bingo advert must not appear again
Ruling on the case, the ASA upheld the complaint. It noted CAP Code guidance that adverts must not “be of strong appeal to children or young persons”.
The Code also states animated content can contribute to the impression the material was designed to appeal to under-18s. As such, ads should avoid using child-like background imagery.
The ASA said Halloween and the traditions surrounding it were likely to have strong appeal for children. It also noted cartoon imagery in the ad was reminiscent of children’s cartoons and story books, while the term “monster” may appeal to children.
As such, it considered the ad was likely to be of strong appeal to children.
The ASA went further to say it would be acceptable for the advert to appear in a medium where under-18s could be excluded from the audience. However, this could only be for circumstances where those who saw the ad had been robustly age-verified as being 18.
As Facebook is a media environment where users self-verify on customer sign-up and do not use robust age-verification, the ASA considered Buzz Bingo had not excluded under-18s from the audience with the highest level of accuracy required for ads where content was likely to appeal strongly to under-18s.
The ASA also acknowledged the steps that Buzz Bingo took in response to the complaint. However, it concluded the ad was irresponsible and breached CAP Code rules 16.1 and 16.3.12.
Buzz Bingo was ordered to ensure the advert must not appear again in this form. The ASA also urged the operator not to include themes or imagery likely to have strong appeal to those under 18 years of age in future ads.