The Advertising Standard Authority (ASA) has upheld a complaint against Buzz Bingo, that advertised a  a Facebook advert that included a cartoon figure of a woman in a box labelled “[NAME] ACTION FIGURE”.

Two complainants challenged whether the ad included imagery which was likely to be of strong appeal to those under 18 years of age and therefore breached the code.

Buzz Group Ltd stated that they did not believe the ad was of strong appeal to those under 18 years of age. They explained that the individual featured in the ad was the General Manager of Buzz Bingo Grimsby; an employee with no celebrity or influencer status who was not widely recognisable.

They considered 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 items 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 post was aimed at a local audience using a staff member in a humorous format for community engagement.

Buzz Group stated that whilst the post was associated with a popular trend on social media, they believed they had incorporated it into their ad responsibly. They stated the social media trend itself did not inherently target or appeal to children and was used widely across different demographics and platforms.

The ASA understood that the format of the ad was based on a popular online trend in which people used artificial intelligence to generate images of themselves as dolls or action figures. The figure in the ad was labelled “[NAME] ACTION FIGURE”, and 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.

The items which accompanied the figure in the box had a similar realistic and muted aesthetic and were associated with the game of bingo, which we considered was not an activity that was likely to appeal to most under-18s. The ASA therefore concluded that the ad was not likely to be of strong appeal to those under 18 years of age.