Advertisment
A video advertisement on YouTube featured a man sitting in what appeared to be a garage waiting area. The sound of a car key ‘beeping’ behind him prompts him to open the Play Ojo app. A voiceover says ‘sounds like Ojo time’. Suddenly various figures in costumes appear around the man, one man dressed as money, another as the car wash brush. A close up of the man’s phone shows him playing a ‘Money Stacks’ casino game
The voiceover stated “feel the fun with all the latest slot and live casino games. No wagering required. So what you win is yours to keep.”
The man and all the characters were then shown dancing.
On screen text said “feel the fun. Play Ojo”.
Complaint
The complainant objected to the placement of the advertisement during video games reviews as they believed that the content was primarily viewed by children.
Response
The advertisers stated that their digital marketing team utilised tools that were provided to them by the platform in order to safeguard against showing their ads to audiences that they shouldn’t be exposing their advertisements to.
In the case of their YouTube ads, they said that they used Google Ads through which they traffic their ads, where they implemented a number of measures within their targeting parameters, both from a Demographic and a Contextual perspective, which addressed the concern that an individual under 18 might potentially see their advertisements. They listed the measures as follows:
• Advertisements show up only to logged in YouTube users,
• They set their campaigns to target ages of 25+,
• They exclude ‘Unknown’ ages where Google doesn’t have the data needed to determine the age of the user,
• They selected to exclude content labelled as Tragedy and Conflict,
• Exclude content that is not yet labelled
• Selected that their adverts to not appear in live streaming videos
• Selected to exclude content suitable for families (which Google defines as Content that’s suitable for families to view together, including Made for Kids videos on YouTube)
They said that the above were a robust set of measures that, in a closed off environment such as YouTube, covered them in terms of compliance with regard to standards.
The advertisers said that their approach was to fully avoid showing advertisements to people under 25 years old, regardless of which channel their advertisements show on, therefore the measures they take avoided altogether their adverts being shown to non-appropriate age individuals no matter the channel they were served on. Therefore, even if it was debatable whether a channel was specifically intended for children or not, which was the case with the channels reported, advertisements would not be shown to non-appropriate aged individuals viewing that channel.
Finally, they said that they were committed to adhering to all relevant marketing guidelines and had processes and procedures in place to ensure they do.
Conclusion
Complaint Not Upheld.
The Complaints Council considered the detail of the complaint and the advertisers’ response.
The Council noted that the complaint had been submitted on the grounds that the advertisement had been served to them while watching content that they considered was attractive to under 18’s. In this case, the Council noted the steps taken by the advertisers to ensure that their advertisements were not served to those under 25 and in the circumstances, did not consider that the placement of the advertisement was directed at those under 18 and was not in breach of the Code on the grounds raised.
Action Required:
No further action required.
