UK ad watchdog clears Buzz Bingo use of action figure trend
The bingo operator’s use of the social media trend would not have appealed to children.
UK.- The Advertising Standards Authority (ASA) has rejected two complaints against a Buzz Bingo social media post that jumped on the the trend of using AI-generated images of action figures. The watchdog decided that despite the image showing a children’s toy, it was unlikely to appeal to minors.
The image was used in a post on Buzz Bingo Grimsby’s Facebook page in April. It showed an image of a cartoon figure of a woman in a box labelled “[NAME] ACTION FIGURE”. The box contained a bingo dabber, bingo cards, and a numbered ball. A caption on the post stated: “For a limited time only Buzz Bingo Action Figures [crying laughing face emoji] Only available at Buzz Bingo Grimsby!”
Two complainants challenged whether the ad included imagery which was likely to be of strong appeal to those under 18 years of age, thus breaching the CAP Code. However, Buzz Group said the image in the ad used the likeness of its Grimsby venue’s general manager, noting that she was not a celebrity or influencer status and was not widely recognisable.
It also argued that the style and presentation of the image was neutral in tone. The cartoon figure appeared in plain office clothing and was not smiling. The objects accompanying her were “intrinsically associated with the game of bingo” and did not incorporate design elements that might typically appeal to children, such as bright, cartoon like graphics or licensed characters. The operator said the post was aimed at a local audience using a staff member in a humorous format for community engagement.
It added that while the post was associated with a popular trend on social media, it believed it had incorporated it into the ad responsibly. It noted that the trend itself did not target or appeal to children and was used widely across different demographics and platforms.
It also stressed that the Buzz Bingo Grimsby Facebook page uses Meta’s platform controls to restrict access to users who had self-verified as 18 and over and that the post was only visible to users logged in to their Facebook account and already following the page. It noted that the Industry Group for Responsible Gambling (IGRG) considers Facebook’s platform controls sufficient for compliance with gambling marketing requirements.
The ASA ruled: “We considered that action figures or dolls were likely to appeal to some under-18s. However, we considered that despite the image being computer-generated, the overall style of the ad was realistic rather than cartoon-like. The figure depicted was an adult who did not have exaggerated features, was wearing a simple shirt, and was not a recognisable or well-known character.
“The colours were muted rather than bright and were not reminiscent of dolls or action figures that were typically marketed towards children. We considered that the ‘action figure’ depicted was unlikely to be viewed by children as an appealing toy to play with.”
Researchers at Bristol University recently lodged a complaint with the ASA about promotional content created by the online betting operator Midnite. They claim that the fast-growing operator has breached rules that prohibit gambling ads from using material that would have a strong appeal to minors with posts on X that included pictures and jokes involving high-profile footballers like Harry Kane, Harry Maguire and Jack Grealish.
In February, Stake pulled out of the British market after the Gambling Commission placed its licence under supervision due to a promotional stunt featuring a porn star outside Nottingham Trent University.
