Who: The Jury of ethical advertisement of the ARPP (independent authority, handles customer complaints concerning ads that seem to breach the codes).
Where: France
When: published on the 6th of July 2017
What happened:
In March 2017, the French lottery operator launched a digital campaign targeting a new audience (18/30 years old) in order to renew its brand image. This commercial had only been digitally broadcasted for a month.
This ad named “Unlock Your Life – Escape Game Loto” is inspired from “the Escape Game”, a new entertainment concept where people are locked inside a themed adventure room and must try to escape before the time runs out. The commercial shows someone evolving in a small apartment full of pizza boxes piling up, dirty laundry, and unpaid bills spread on the floor. The ad features punch lines such as “stuck in your shit?”, “there’s a way to escape”, “find the 6 right digits”, and the final signature is “unlock your life”, “get out of your routine”.
The real game takes place in the same setting as the commercial (in Paris). A lottery number is revealed each time the players solve an enigma. The players that manage to find the 6 lottery digits before the end of the game automatically participate in a lottery draw contest. The winner will earn six months of rent.
Two private individuals referred this commercial spot to the Jury of ethical advertisement of the ARPP. ARPP’s goal is to maintain high standards in terms of legal, honest and truthful advertising, which is the interest of both consumers and the advertisers. Digital advertising is one of the main concerns of the ARPP and its work in this domain is fundamental as it is illustrated in the Recommendation “Gambling”.
The complainants argued that the said commercial was in contradiction with this Recommendation for several reasons:
- First of all, the message of the commercial is not clear. Indeed the character seems to live in poverty which is emphasized by many clichés such as difficult mornings, unpaid bills, and an empty fridge. The commercial mentions slogans such as “there is a way to escape“. The consumers can wonder if this is a way to escape from the room or from poverty. This double meaning is in conflict with the Recommendation that provides that lottery games shall not arouse fear in the consumer.
- The Recommendation also prohibits commercials from suggesting that gambling helps with financial problems. According to the complainants, this commercial spot explicitly suggested that gambling is “a way to get out” when one is “stuck in problems”.
- Finally, if the Recommendation prohibits implying that gambling is a way to earn a living rather than an entertainment; the said commercial focuses on the fact that finding the 6 digits will help to escape from poverty.
According to the announcer, this commercial was meant to represent a small student accommodation and to revisit some clichés that revolve around uni students. It is important to highlight the fact that no reference to the lottery is really made in the video. The main goal was the promotion of a free promotional game in the context of an advertising campaign whose theme is to “bring a bit of luck into your life”, and not to promote the lottery. Consequently, in his opinion the cumulative criteria for the application of the Recommendation “gambling” were not fulfilled.
Jury’s decision
The Jury found that even though the ad does not directly promote gambling (only a teaser) the ad aims to bring the existence of the lottery to the attention of a younger public and as a consequence enters into the scope of the said Recommendation.
Why this matters:
Announcers must take into account ARPP’s recommendation when designing their commercials. Several rules must be respected when it comes to gambling activity.
This is a question of balance between free advertising and protection of the public. Here the targets were people ranging from 18 to 30 years old which are identified as a vulnerable group and it did not play in favour of the French lottery operator.
