This policy applies to the business activities of Begame Group (Begame) in Great Britain (GB), principally Begame’s GB-facing remote gambling (casino and bingo) websites, which the Gambling Commission of Great Britain licenses through Begame’s licensing entity, Dazzletag Entertainment Limited.

This policy extends to all marketing activity conducted by and on behalf of Dazzletag Gibraltar Ltd, a subsidiary wholly owned by Dazzletag Entertainment Ltd and part of the Begame group of companies. As such, this policy covers all Dazzletag Gibraltar Ltd activities, employees, and marketing partners.

This policy is relevant to the marketing and advertising currently conducted by Begame, including non-broadcast advertising via affiliate partners. All affiliate partners contracted through GoGame Partners (Begame’s affiliate platform) must follow this policy in the marketing and advertising of Begame brands. This policy applies to affiliate partners and Begame employees equally.

Begame does not currently conduct any broadcast advertising; therefore, relevant broadcast codes are not within the scope of this policy. Policy documents will be updated to reflect our approach if this changes.

 

All Begame marketing, advertising and promotional activity will be conducted in accordance with the relevant licensing guidelines and legal requirements. For the GB market, these include:

 

2.1 UK Code of Non-broadcast Advertising and Direct and Promotional Marketing (CAP Code)

 

The Advertising Standards Authority (ASA) is the UK’s independent advertising regulator. The ASA ensures that advertisements across UK media adhere to the advertising rules (the Advertising Codes). The Committee of Advertising Practice (CAP) is the sister organisation of the ASA and is responsible for writing the Advertising Codes. The full CAP Code is available here: CAP Code.

The ASA is responsible for publishing marketing guidance for the gambling industry as well as handling complaints about inappropriate or misleading advertising. The rules in this section apply to all Begame marketing: 

2.1.1 Misleadingness

Marketing communications must not materially mislead or be likely to do so and must state all significant limitations and qualifications. Online ads must also direct consumers to a source where the full terms are stated, which must be no further than one click away from the ad.

Full guidelines in this area can be found here: ASA Code Section 03. Examples most relevant to Begame’s activity include:

·       Obvious exaggerations (“puffery”) and claims that the average consumer who sees the marketing communication is unlikely to take literally are allowed provided they do not materially mislead.

·       Marketing communications must state significant limitations and qualifications. Qualifications may clarify but must not contradict the claims that they qualify.

·       Marketing communications must not claim that products can facilitate winning in games of chance.

·       Marketing communications must make clear the extent of the commitment the consumer must make to take advantage of a “free” offer

·       Marketing communications must not describe items as “free” , “gratis”, “without charge” or similar if the consumer has to pay anything other than the unavoidable cost of responding and collecting or paying for delivery of the item.

·       marketing communications must not mislead consumers by omitting restrictions on the availability of products; for example, geographical restrictions or age limits

 

2.1.2 Promotional Marketing

The promotional marketing rules apply to player promotions and incentive schemes. They regulate the nature and administration of promotions.

Full guidelines can be found here: ASA Code Section 08. Examples most relevant to Begame’s activity include:

·       Promoters must conduct their promotions equitably, promptly and efficiently and be seen to deal fairly and honourably with participants and potential participants. Promoters must avoid causing unnecessary disappointment.

·       Promotions must not be socially undesirable to the audience addressed by encouraging excessive consumption or irresponsible use.

·       Promoters must do everything reasonable to ensure that unsuitable or irresponsible material does not reach consumers or other recipients.

·       No promotion or promotional item should cause serious or widespread offence to consumers.

·       Special care must be taken with promotions addressed to children or if products or items intended for adults might fall into the hands of children.

·       Phrases such as “subject to availability” do not relieve promoters of their obligation to do everything reasonable to avoid disappointing participants.

·       If a prize promotion is widely advertised, the promoter must ensure the widespread availability of the requisite forms and any goods needed to establish proof of purchase.

·       Promoters must award the prizes as described in their marketing communications or reasonable equivalents, normally within 30 days.

·       All marketing communications or other material referring to promotions must communicate all applicable significant conditions. Please see section 5 for more information on Begame’s approach to significant terms and conditions.

·       Promoters must not exaggerate consumers’ chances of winning prizes. They must not include a consumer who has been awarded a gift in a list of prize winners.

·       Promoters must not claim or imply that consumers are luckier than they are.

·       Promoters must not falsely claim or imply that the consumer has already won, will win or will on doing a particular act win a prize (or other equivalent benefit) if the consumer must incur a cost to claim the prize (or other equivalent benefit) or if the prize (or other equivalent benefit) does not exist.

 

2.1.3 Gambling

 

The rules in this section of the CAP code are designed to ensure that marketing communications for gambling are socially responsible, with particular regard to the need to protect children, young persons, and other vulnerable persons from being harmed or exploited.

Full guidelines can be found here. Examples relevant to Begame’s activity include:

·       Marketing communications for gambling must be socially responsible, with particular regard to the need to protect children, young persons and other vulnerable persons from being harmed or exploited.

·       Marketing communications must not:

o   portray, condone or encourage gambling behaviour that is socially irresponsible or could lead to financial, social or emotional harm

o   exploit the susceptibilities, aspirations, credulity, inexperience or lack of knowledge of children, young persons or other vulnerable persons

o   suggest that gambling can provide an escape from personal, professional or educational problems such as loneliness or depression

o   suggest that gambling can be a solution to financial concerns, an alternative to employment or a way to achieve financial security

o   portray gambling as indispensable or as taking priority in life; for example, over family, friends or professional or educational commitments

o   suggest that gambling can enhance personal qualities, for example, that it can improve self-image or self-esteem, or is a way to gain control, superiority, recognition or admiration

o   suggest peer pressure to gamble nor disparage abstention

o   link gambling to seduction, sexual success or enhanced attractiveness

o   portray gambling in a context of toughness or link it to resilience or recklessness

o   suggest gambling is a rite of passage

o   suggest that solitary gambling is preferable to social gambling

o   be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture. They must not include a person or character whose example is likely to be followed by those aged under 18 years or who has a strong appeal to those aged under 18.

o   be directed at those aged below 18 years

o   include a child or a young person. No-one who is, or seems to be, under 25 years old may be featured gambling or playing a significant role. No-one may behave in an adolescent, juvenile or loutish way.

o   exploit cultural beliefs or traditions about gambling or luck

o   condone or encourage criminal or anti-social behaviour

o   condone or feature gambling in a working environment.

 

2.2 Gambling industry code for socially responsible advertising

The Gambling Code of Socially Responsible Gaming applies a number of industry standards in limited areas not covered by CAP/ BCAP. The Code sets minimum industry standards for gambling advertisements.

Full details of the code can be found here: https://bettingandgamingcouncil.com/members/igrg

Key Requirements of the code in relation to Begame activity:

1. Include reference to www.gambleaware.org in all print and broadcast adverts – para 27

2. www.gambleaware.org must be presented in accordance with the requirement – para 30

8. Online banner advertising click-through – para 47

11. Social Media marketing – paras 53-55

12. Promoting consumer awareness – para 57

13. Keyword blacklist – para 59

14. Affiliate activity – para 61

Begame marketing communications must not include a child or a young person. No one who is, or seems to be, under 25 years old may be featured gambling or playing a significant role.

Begame marketing communications for gambling must not be likely to strongly appeal to children or young persons, especially by reflecting or being associated with youth culture, particularly if they are generally available to be viewed by them (‘freely accessible’).

Begame will take care with the use of imagery, wording, and characters used in marketing communications. Ads will not include a person or character whose example is likely to be followed by those aged under 18 years or who has a strong appeal to those aged under 18, such as sportspeople and celebrities.

 

4.1 Significant Terms

Begame will ensure that marketing communications do not mislead consumers. All significant terms and conditions that are likely to affect a consumer’s understanding of a marketing promotion must be prominently displayed within the advertisement and positioned close to the headline offer on all relevant landing webpages and sign-up webpages (or equivalent) for that promotion, unless the advertisement is so small that it is impossible to do so.

Significant terms and conditions include:

·       Player Type: New Players Only, Funded Players Only, Bronze Players Only.

·       Deposit requirements: Minimum and maximum required to claim the offer.

·       Bet requirements: “Play £5 cash in Bing Bling to get £10 bingo bonus”

·       Wagering or fund withdrawal requirements.

·       Time limits: Bonus expiry once awarded, Bonus code or promotion end date, one entry per day etc.

·       Entry Requirements: Collect X tickets during December to enter our big £10,000 game.

·       Winnings Caps

·       Bonus Type: Bingo Bonus or Casino Bonus

·       Game or Room Type: 10 free spins on Starburst Slot, 10 free tickets for Bing Bling etc.

Significant conditions will be clear, timely, intelligible, unambiguous, non-misleading and transparent. The terms and conditions of each marketing incentive will be made available for the full duration of the promotion.

Prize Advertising

If a singular prize is available, we can use the term “Win”. However, if a prize is split between players within a session you must state that the prize is shared. 

 

For example, £10,000 is given away in one game in the following way:

 

·       1 line: £1,500

·       2 lines: £3,500

·       Full House: £5,000

 

We may say something like this:

 

·       Win a share of £10,000

·       Win up to £5,000

 

If the prize is won over a number of games we may not call it a game you must call it a session.

 

If the prize is given out at the end of a tournament, you should make it clear how to qualify for the end prize. For example:

 

“Collect tickets during December to enter our big £10,000 free bingo session.”

 

Begame will take steps to ensure that it will not place digital advertisements on websites providing unauthorised access to copyrighted content;

 

Begame will ensure that all third parties and affiliates advertising on its behalf do so in a socially responsible manner and follow the regulations and rules issued by the relevant authorities.

Under its license, Begame is ultimately responsible for all marketing conducted by its affiliates. Therefore, close control and monitoring of all affiliates are critical.

Begame has its own affiliate program called GoGame Partners, which operates on the Income Access platform. Any partner wishing to conduct marketing on behalf of Begame must open an account using the GoGame Partners website and agree to the Terms and Conditions, which include compliance with this policy.

All affiliates must comply with all relevant regulatory and legislative requirements, including CAP’s guidance on ensuring advertisements are obviously identifiable as such.

A separate procedure documenting how affiliates are managed and monitored has been published.

Affiliates must share safer gambling-related content regularly. Begame will terminate relationships with affiliates who cannot/do not comply with this policy or the general terms and conditions set out on the GoGame Partners website.

Begame follows necessary regulatory codes in regards to the opt-in for marketing material and managing consent going forward including General Data Protection (GDPR) regulations and the Privacy and Electronic Communications Regulations (PECR).

 

While consent boxes are selected for the customer as opted in under the “Soft Opt-In” principle, the user has the option to withdraw their consent at any time via the My Account page or through links from marketing material.

The soft opt-in principles means that we may be able to email or text your own customers, but it does not apply to prospective customers or new contacts.

In accordance with guidelines under soft opt-in principle, Begame ensures the following:

–        We only send electronic mail with consent (unless contacting previous customers about our own similar products, and we offered them an opt-out when they gave us their details).

–        We offer an opt-out (by reply or unsubscribe link) and act on this promptly.

–        We keep a ‘do not contact’ list of anyone who opts out or unsubscribes from our electronic mail.

–        We screen against our ‘do not contact’ list and we don’t send electronic mail to anyone who has asked us not to.

–        We don’t disguise or conceal who we are when we send electronic mail.

–        We don’t ask or encourage people to forward our electronic mail marketing to their friends or family.

–        We don’t ask people to give us the contact details of their friends and family to use for electronic mail marketing.

Begame will only send marketing emails to its own customers. At present, minimal SMS messages are sent, with these tending to be service or responsible gambling related alerts.

Training on Begame’s Marketing & Advertising Policy is provided during employee induction. Further detailed training via the iGaming Academy online resources will be provided to all employees involved in creating promotional and advertising content.

Refresher training will be provided every three years or upon significant policy changes, whichever comes first.

Begame has implemented a clear approval process for all advertising and promotional content to help ensure compliance with this policy.

Creatives for website and affiliate marketing advertising, such as affiliate banners, website headers, social media images, email banners, splash pages, and landing pages must be approved by one of the Begame compliance team members, consisting of:

• Daniel Williams – Chief Operating Officer
• Darren Styne – Payments & AML Manager

Assets and promotions can be submitted for approval using the compliance inbox: compliance@begame.com. For operational efficiency, previously approved graphics and promotional mechanics can be used with minor tweaks. For example, a landing page can be reused with a game image substituted, or a common bonus mechanic, such as a reload bonus, can be reused with the same terms and conditions.

Affiliates must use pre-approved assets that are uploaded via the GoGame Partners affiliate portal. If other non-portal assets are to be used, they must be approved by the Begame compliance team via the compliance inbox.

The Begame compliance team will verify compliance with this policy through various methods, including but not limited to periodic walk-throughs, business tool reports, internal and external audits, and feedback to the policy owner.

Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. In line with our marketing partner agreement, any third party found to have violated this policy may have their agreement terminated and all commissions retained.