November 28, 2022
The advice note looks at a range of rules that might be relevant to ads for mobile games.
First up is avoiding harmful or offensive imagery. The Committees point out that by their very nature, harm and offence issues will contain elements of subjectivity. Therefore, considerations will be case-by-case. Marketers should be mindful of the impact that the content of their ads have and be cautious about crossing into problematic territory.
For example, while depicting people in a sexual way is not always offensive or harmful, marketers should take care to ensure that they do not over-sexualise or objectify those that are featured. In Higgs Technology Co Ltd 31 (August 2022), an ad for a puzzle game was considered problematic on this point because it included an animation depicting a female character, who appeared to be naked behind some tiles, while implying that moving them would further expose the character. The ASA found that the imagery had been used with the sole purpose of titillating viewers.
There are also specific rules prohibiting ads from portraying anyone who is, or seems to be, under 18 in a sexual way. In Oasis Games Ltd, (28 September 2022), an ad for a game that included an anime/manga-style image of a young woman in a cage fell foul of this rule as the character’s face appeared youthful and a caption referred to her as a “LITTLE GIRL”.
Obviously, portraying scenarios depicting assault or abuse will almost certainly be problematic and, as demonstrated in AppQuantum Publishing Ltd (24 November 2021), attempts at humour are unlikely to be a suitable defence if, overall, the effect of the content is likely to be seen as trivialising and condoning domestic abuse.
Depicting stereotypical roles or characteristics in a way that suggests that they are always uniquely associated with one gender are also likely to be problematic.
Next, the Committees consider the issue of targeting, advising that marketers need to be careful when placing ads for mobile games within other mobile games. This is particularly true for ads that include adult themes, such as violence or sexually suggestive content.
Finally, the Committees consider the issue of misleading claims, reminding marketers that they must ensure that any visuals or game descriptions accurately represent the game being advertised. In PLR Worldwide Sales Ltd t/a Playrix (30 September 2020), two Facebook posts advertising mobile games included visuals of specific puzzle-solving sequences, which was not representative of the overall game. In that ruling, the ASA said it was not sufficient to include qualifications, such as “Not all images represent actual gameplay”, not least because users would have to play a significant amount of content that was different in style in order to access the limited amount of gameplay that was featured in the ads. To read the advice note in full, click here.