a. An online video ad promoted the Isuzu D-Max Blade truck. It appeared as a banner ad on various websites, including the advertiser’s own. It depicted the truck as the hero in a zombie infested city. b. The same video appeared as an in-game ad that appeared in the app ‘Scrabble Free’.
The ASA received seven complaints.
- All of the complainants challenged whether the content was distressing and offensive, because it was excessively gory and frightening.
- Four of the complainants challenged whether ad (a) had been irresponsibly placed where it could be seen by children.
- Three of the complainants challenged whether ad (b) had been irresponsibly placed in an app that could be played by children.
1. Not upheld
The ASA noted that the ad featured a number of zombies that were injured and covered in blood. We noted that while the main protagonist, within the Isuzu truck, was surprised and unsettled by the sudden appearance of zombies, his reaction was measured and he was not shown to be in immediate danger. Similarly, while a woman featured in the ad was shown to be trapped on the roof of a car trying to fend off a group of zombie attackers, we considered it was clear from the man’s reaction that he intended to save her. While we acknowledged that some viewers might find the ad unpleasant and unsettling, and that the it would need to be targeted carefully to ensure it was not seen by young and early teenage children, who could be distressed and upset by its content, we concluded that it was not overly graphic, violent or threatening, and was unlikely to cause serious or widespread offence.
We considered that the content of the ad could distress young and early teenage children, and therefore needed to be targeted carefully. We noted that the ad was targeted at users who were identified, through their browsing behaviour, to be male, over 18, and interested in cars. We understood, however, that such targeting could not mitigate the possibility of a child sharing a device, and the same browsing session, with an adult, and therefore seeing the ad during that session. While we appreciated that parents or guardians could take action to minimise that risk by deleting their browsing history or opting out of behavioural advertising, we considered that many parents would not necessarily be aware of such targeting methods or the steps they could take to avoid being served targeted ads. We understood that the network did not serve ads on any sites that were predominantly aimed at children and so the ad would not have appeared on sites of particular appeal to children, even if the device’s browsing history indicated that the user was an adult male. We were concerned, however, that the ad could nonetheless appear on sites regularly used by children. We noted from the data provided that sparknotes.com was visited by a large number of individuals aged between the ages of 13 and 17, and that, depending on who else shared the same device, children visiting the site could have been served the ad.
In light of that risk, and because the way the ad was targeted it could not take into account the possibility of a child and adult sharing the same browsing session, we considered that Isuzu had not taken the necessary precautions to mitigate the risk of a child viewing the ad, such as ensuring the ad did not appear on sites regularly used by children.
Despite the targeting steps taken by the advertiser, because the ad appeared on a website regularly used by young teenagers, we concluded that it had been irresponsibly targeted.
We understood that the ad was targeted to app users depending on their browsing history, and so would only be shown in-app to those who appeared to be over the age of 18. We noted, however, that the app was deemed to be suitable for those aged four and over, and that parents might allow a child to play with the app believing that the content, including all in-app advertising, would be suitable for that age range. In particular, we considered that a parent who might not usually allow a child to browse the internet independently on a device, might be more inclined to allow them to play an age-appropriate app. Therefore, we were concerned that an adult and child could share a device within the same browsing session, and the child could have been served the ad while playing Scrabble Free.
In light of that risk, and because the way the ad was targeted it could not take into account the possibility of a child sharing a device with an adult, we considered that Isuzu had not taken the necessary precautions to mitigate the risk of a child viewing the ad, such as ensuring the ad did not appear in apps with a low age rating.
Despite the targeting steps taken by the advertiser, because the ad appeared in an app which was rated suitable for children, we concluded that it had been irresponsibly targeted.
The ad must not appear again in its current form. We told Isuzu (UK) Ltd to carefully target their ads to avoid the risk of causing undue fear and distress to children.