ASA Rules Against Smart Gravity Over Gambling-Help Search Ad

The Advertising Standards Authority upheld a complaint against Smart Gravity Ltd, trading as the affiliate comparison site top10onlinecasinoreviews.co.uk, after a paid-for search ad promoting casino websites appeared in response to a search for “help with gambling.” The regulator published its ruling on September 9, 2026, recording that the ad had not been responsibly targeted and had breached the UK advertising code’s social responsibility rule.

The Ad and the Complaint

The ad was a paid-for search ad for top10onlinecasinoreviews.co.uk, seen on June 18 following a search for “help with gambling.”

Text in the ad read: “UK’s Top 10 Casino Sites – 10 Best Casino Online Sites UK … Compare The Best Online Slots Sites In The UK 2026. Fast Signups & Mega Bonuses To Claim. The Only Casino List Compiled Of Real Users Ratings! Signup & Enjoy Our Brilliant Offers.”

The complainant challenged whether the ad was irresponsibly targeted.

Smart Gravity’s Response

Smart Gravity told the ASA it was an affiliate comparison website and did not operate gambling services itself. Its website provided comparison content, reviews and information relating to operators licensed by the UK Gambling Commission.

The company said it understood the ad had been served by Microsoft Advertising. On receiving the complaint, it initiated an internal investigation to establish how the ad had been served, reviewing its campaign settings, keyword targeting, search-term data and compliance procedures to determine whether any additional safeguards were appropriate. It said its campaigns were configured to target adult users in the UK using the targeting controls available within the advertising platform.

Smart Gravity said it maintained an ongoing compliance framework intended to minimise the likelihood of its ads appearing alongside inappropriate search queries, including periodic reviews of campaign settings and targeting, continuous review of negative keyword exclusions and internal compliance monitoring. It said it had no commercial interest in advertising to individuals seeking support for gambling-related harm and did not intentionally target vulnerable consumers, underage users or individuals seeking gambling support or self-exclusion services. Its intended audience, it said, consisted of adults seeking information about licensed gambling operators.

The company provided its negative keyword list, which it said was designed to exclude its ads from appearing in results for searches relating to gambling addiction, safer gambling and topics related to gambling harm. It said that while automated systems could not guarantee that every possible keyword match would be prevented, it continuously reviewed its controls to reduce that risk as far as practicable.

Smart Gravity said its advertising strategy used a combination of Exact Match, Phrase Match and Broad Match keywords. It said it had not identified any search queries containing the phrase “help with gambling” that had been matched to the keywords it used, and it provided two screenshots of Search Term Reports from its Microsoft Advertising account showing the search terms and wording consumers had used when its ads were displayed.

The ASA’s Assessment

The ASA considered that, by searching for the phrase “help with gambling,” a consumer was likely to be seeking information, advice and support about gambling-related harms, and that such consumers were likely to include vulnerable persons looking to manage or reduce their exposure to and engagement with gambling ads. In that context, it considered that an ad promoting online casino sites with “Fast Signups” and “Mega Bonuses” was not appropriate to appear in response to that search.

The regulator acknowledged that Smart Gravity operated an affiliate comparison website rather than a gambling service, but considered that the ad had the effect of promoting online casino and gambling sites. It noted that the Code requires ads for gambling to have particular regard to the need to protect vulnerable persons from being harmed or exploited, and said it expected marketers placing ads for gambling-related services to have very robust controls in place to prevent their ads from being inappropriately targeted, because of the potential for considerable harm to vulnerable consumers.

The ASA acknowledged the company’s negative keyword list but observed that Smart Gravity used a mix of broader keyword-matching options, some of which meant its ads could be displayed when a consumer searched for terms that related to, but did not contain, the keywords targeted by the advertiser. It considered that the use of broader matching created a risk the ad would be served in response to searches indicating that a consumer might be experiencing gambling-related harm.

In those circumstances, the ASA concluded, the negative keyword list and targeting controls had not provided a sufficiently robust safeguard against the ad being shown to potentially vulnerable consumers. Because it considered there was a strong likelihood that vulnerable consumers seeking to reduce their exposure to and engagement with gambling ads and websites had been served an ad promoting casino websites following a search for “help with gambling,” the regulator concluded the ad had not been responsibly targeted.

Social Responsibility Rule and Required Action

The ASA recorded that the ad breached rule 1.3 of the CAP Code (Edition 12), covering social responsibility. The rule states: “Marketing communications must be prepared with a sense of responsibility to consumers and to society.” The Code’s central principle is that all marketing communications should be legal, decent, honest and truthful and should reflect the spirit, not merely the letter, of the Code.

The CAP Code is the rule book for non-broadcast advertisements, sales promotions and direct marketing communications, and must be followed by all advertisers, agencies and media. It is enforced by the ASA, which can take steps to remove or have amended any ads that breach the rules. Its Section 16 sets out social responsibility rules for gambling and spread betting whose content and targeting rules are designed to protect under-18s and the vulnerable.

Under the ruling’s recorded action, the ad must not be served following the search for “help with gambling” again. The ASA told Smart Gravity Ltd, trading as top10onlinecasinoreviews.co.uk, to ensure that its search ads were responsibly targeted.