On the 9th of September, the ASA released a new ruling against Smart Gravity Ltd trading as top10onlinecasinoreviews.co.uk after receiving a complaint about a paid for ad was seen. The complainant challenged whether this ad was irresponsibly targeted after it was seen following a search for “help with gambling”.

The ad in question showed text that stated “UK’s Top 10 Casino Sites – 10 Best Casino Online Sites UK […] Compare The Best Online Slots Sites In The UK 2026. Fast Signups & Mega Bonuses To Claim. The Only Casino List Compiled Of Real Users Ratings! Signup & Enjoy Our Brilliant Offers”.

Smart Gravity Ltd is an affiliate comparison website and do not provide gambling services themselves but compare content, reviews and information related to licenced operators within the UK. In response to the complaint, Smart Gravity Ltd conducted an internal investigation, reviewed their campaign settings, keyword targeting, search-term data, and compliance procedures to determine whether additional safeguarding measures were appropriate. They also went on to say that their campaigns are configured to target adult users in the UK and maintain an ongoing compliance framework to minimise the likelihood that the ads would appear alongside “inappropriate search queries”.

The company also provided their negative keyword list, designed to exclude their ads from appearing in results for searches relating to gambling addiction, safer gambling, and topics related to gambling harm. They continued to state that whilst these systems cannot guarantee that every possible keyword match would be prevented, the controls are continuously reviewed to reduce that risk.

The ASA found that the safeguards in place were insufficient and that someone searching “help with gambling” would likely be seeking support for gambling related harm, therefore potentially being a particularly vulnerable individual and so considered that more robust controls are required.

Due to this the ASA found that the ad was irresponsibly targeted and breached CAP Code rule 1.3 and so the complaint was upheld. Smart Gravity were instructed to not allow the ad to appear following the same search again and ensure advertising is responsibly targeted.

OUR RECOMMENDATIONS
• Ensure any affiliate marketing material is appropriate and does not target vulnerable individuals
• Review and test affiliate marketing compliance regularly
• Remember, members can contact the Betting and Gaming Council for the up to date banned keyword list!

If you have any questions, please do not hesitate to Contact Us

LINKS TO FULL DETAILS
See the ASAs release HERE
View the Industry Code for Responsible Gambling details HERE