oth promotions were published during the Euro 2016 football tournament and sent out in June this year.
The first offered players that bet €/£20 on a team to win the tournament a free €/£10 bet each time a British team scored in the opening round of matches. Three customers complained after placing a bet to take advantage of the offer, only to be told they were ineligible.
"An email from Coral Interactive, promoting a free bet offer, received in June 2016 stated 'Bet £/€20 on any team to win the Euros & get a free £/€10 bet every time a British or Irish team scores in the first round of matches'," the ASA said in its ruling adding that "three complainants, who received the email and after placing their bets were informed that they were not eligible to participate in the offer, challenged whether it misleadingly implied the offer was open to all recipients."
Following is the complete ruling by the ASA on the first add:
"Coral Interactive (Gibraltar) Ltd explained that the email contained a targeted promotion which was only valid for selected customers, but due to human error it had been sent to some customers who were restricted from receiving free bets and therefore would not have been able to claim the promotion. They explained that when they realised the error, they had taken immediate steps to rectify it. They sent a follow-up email to advise those customers that they were in fact not eligible for the promotion and apologising for any inconvenience caused.
"The ASA noted the email had been targeted at specific individuals and was addressed to the name of the recipient. We considered that anyone receiving the email would expect they could take advantage of the free bet offer. However, we understood that was not the case, because the email had been sent in error to some customers who had restricted accounts.
"Given that they were therefore not eligible for the offer, we considered those customers had been caused unnecessary disappointment. Moreover, because the ad implied that anyone receiving the email was eligible to take up the offer, when that was not the case, we concluded that it was misleading. We welcomed Coral Interactive's willingness to take steps to rectify the error.
"The ad must not appear again in its current form. We told Coral Interactive (Gibraltar) Ltd to ensure in future their promotional advertising did not misleadingly imply that an offer was open to everyone, unless that was the case."
Regarding the second add, the ASA said:
"An email and a pop-up ad for Coral Interactive, a gambling company, promoted free £10 bets on the outcome of Euro 2016 matches:
a. The email, which was received at 13:37 on 15 June 2016, stated "Bet £/€ 10 on the correct score for tomorrow's highlight game, England v Wales, and if your selection loses, you'll get a £/€ 10 free bet.*". The ad featured two prominent hyperlinks with the text "Bet Now >>". Further text at the bottom of the email stated "Terms and Conditions Apply *£/€10 FREE BET ... Offer valid to bets struck from 8pm BST on the day before the nominated game until kick-off".
b. The pop-up ad, seen on Coral Interactive’s website on 15 June, featured the headline claim "J'adore le Score! Bet £10 on correct Score. Get a £10 Free Bet if your selection loses". Further text stated "We'll select one match to get the J'adore le score' treatment where we're giving you a terrific £/€ 10 free bet if your correct score selection loses. Simply place a correct score bet of £/€ 10 + on selected 'J'adore le score' daily match and if your bet doesn't win, we'll give you a £10 free bet token." Towards the bottom of the ad, there was a hyperlink labelled "Bet Now". At the bottom of the page, the ad stated “Terms and Conditions”. Upon clicking this, the terms and conditions appeared, which included “offer valid to bets struck from 8pm BST on the day before the nominated game until kick-off."
"The ASA received two complaints.
1. One complainant, who noted that customers were only eligible for the free bet if the bet was placed after 8:00 pm, challenged whether ad (a) was misleading by not making this condition sufficiently clear.
2. A second complainant challenged whether ad (b) was misleading for the same reason.
1. & 2. Coral Interactive (Gibraltar) Ltd explained that the promotion was advertised in advance of it going live at 8:00 pm. They said the terms and conditions made clear that the offer was only valid after 8:00 pm, but acknowledged that it was an error not to include that information in the main body of the ads. They apologised for the mistake, and said they had begun taking steps to ensure that time-sensitive promotions always carried significant conditions in the main body of ads, and were also introducing a second internal compliance review of all promotions to ensure fairness and compliance with the Code.
"The ASA welcomed Coral Interactive’s willingness to ensure that future time-sensitive promotions included all significant conditions.
"We noted that the email was received the day before the promoted football match and that the ad featured a prominent “Bet Now” link. We therefore considered that consumers would understand from the claim “Bet £/€ 10 on the correct score … and if your selection loses, you'll get a £/€ 10 free bet”, that if they placed a bet at any time between receipt of the email and the start of the match, and their selection lost, they would receive a free bet.
"We noted that the terms and conditions at the bottom of the email, which could only be viewed after scrolling down, stated “Offer valid to bets struck from 8pm BST on the day before the nominated game until kick-off”. However, we considered that that text could be easily overlooked and was not sufficiently prominent to counter the overall impression that any bet placed after receipt of the email would be eligible for the offer. We considered that the time-restriction was a significant condition and therefore should been included within the main body of the ad. Because the ad did not make the condition sufficiently clear, we concluded that the ad was likely to mislead.
"We noted that the pop-up ad appeared on the advertiser’s website the day before one of the promoted football matches and featured a “Bet Now” link. In that context, we considered that consumers would understand from the claim “Get a £10 Free Bet if your selection loses” and “if your bet doesn't win, we'll give you a £10 free bet token”, that if they placed the bet at any time before the start of their selected match, and their selection lost, they would receive a free bet.
"We noted that by clicking the “terms and conditions” button at the bottom of the ad, consumers could view the conditions of the promotion which included the 8:00 pm time-restriction. However, we considered that the inclusion of the condition “one-click away” was not sufficiently prominent to counter the overall impression of the ad that the offer was already available for customers. As mentioned above, we considered that the time-restriction was a significant condition which should have been included in the main body of the ad. Because the ad did not make the condition sufficiently clear, we concluded that it was likely to mislead.
The ad must not appear again in its current form. We told Coral Interactive (Gibraltar) Ltd to ensure that they made clear all significant conditions of their promotions."