So the initial review of the Interactive Gambling Act has been completed, and the draft report has been released. Everyone’s talking about online gambling at the moment, especially the clubs (who think they should be allowed to run online casinos) and the papers (who most recently discovered that it’s the Australian sports betting sites that are getting most of the online traffic, not illegal offshore casinos). I’ve got plenty to say about both of those… but that will have to wait for another day.
The draft report had a fair bit to say about gambling advertising, and about gambling on smart phones, but very little to say about the combination of the two. And that’s a problem. Because what we have is a situation where inappropriate smart phone apps, gambling or otherwise, are being directly marketed to children of all ages via their smart phones and tablets. This isn’t the future; it’s now.
Smart phone apps follow a rating system. For the iPhone (which is what I have) the ratings are:
4+ Applications in this category contain no objectionable material.
9+ Applications in this category may contain mild or infrequent instances of cartoon, fantasy or realistic violence, and infrequent or mild mature, suggestive, or horror-themed content which may not be suitable for children under the age of 9.
12+ Applications in this category may also contain infrequent mild language, frequent or intense cartoon, fantasy or realistic violence and mild or infrequent mature or suggestive themes, and simulated gambling which may not be suitable for children under the age of 12.
17+ You must be at least 17 years old to purchase this application. Applications in this category may also contain frequent and intense offensive language; frequent and intense cartoon, fantasy or realistic violence; and frequent and intense mature , horror, and suggestive themes; plus sexual content, nudity, alcohol, tobacco, and drugs which may not be suitable for children under the age of 17.
In practice the app rating system is a joke, as it is not enforced (except for a “please confirm you are 17 or older” button when downloading a 17+ app) but it does provide some sort of idea what kind of app you’re downloading. It’s also useful for parents who let their kids play on their smart phones… if an app is 4+, it can’t be too bad.
The problem is that many apps are only free to download if they’re supported by ads. It’s a common tactic for app designers; sell the full version for a dollar or two, and give away a cut down version loaded up with advertising. Either way they get paid.
But this is where it breaks down. There is no regulation or protocol that states that in-game advertising must be appropriate for the app that displays it. You might think it’s common sense that 4+ apps should only be allowed to advertise other 4+ apps, 12+ apps should be allowed to advertise 4+, 9+ and 12+ apps, and so on… not so.
Here’s an example. I have a number of games on my phone, most of which are free versions with advertising support. Three that I play fairly regularly, as do my kids when I let them, are Solitaire, Spider Solitaire and Fruit Ninja Lite. All three of these games are rated 4+, meaning “no objectionable material”.
But that rating doesn’t apply to the ads. In the past week alone all three games displayed the following ads:
The first two are ads for VIP Poker, a 12+ free-to-download, free-to-play poker app.
The rest are for Card Ace Casino, a 12+ free-to-download, free-to-play online casino app.
Both of these apps gained their 12+ rating for containing “simulated gambling”, and while nominally free-to-play, both allow in-app purchases of virtual chips, deals and gambling packs with the capacity to spend hundreds of real dollars playing for virtual winnings.
How can the advertisers get away with promoting these restricted apps from within other unrestricted apps? Because no one’s stopping them.
Sure, I could pay for the full versions of the apps and do away with the ads… but that doesn’t solve the problem. And no one should be put in a position of paying to avoid inappropriate ads… that in itself is a slippery slope that cannot end well. Imagine if your kids were subjected to similar ads while watching Hi-5 or Dora The Explorer… this is the same kind of thing.
There is one other problem with the iPhone app rating system which is also gambling-related. It’s wide open to abuse. Consider the following scenario.
Three of the top ten free sports apps in the iTunes store right now are for sports betting companies. TAB Sportsbet, TattsBet and Sportsbet are numbers 6, 7 and 10 respectively.
Sports betting apps, by nature of their adult-oriented content, attract the 17+ rating. This holds true for all sports betting apps I’ve been able to find, except one. The Sportsbet app is only rated 4+, and as such is freely available to anyone in Australia to download and use, regardless of their age.
No surprise then that while playing Solitaire (with its 4+ rating) recently, I was also confronted by these ads:
Sportsbet’s actions in classifying their gambling app as 4+ are beneath contempt; but so too is the system that allows them to do so. Smart phone providers and advertisers need to clean up their act… but they won’t unless someone makes them, and that isn’t going to happen any time soon.