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  1. #1
    tup's Avatar
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    Default Gamesys Affiliates - Explicit consent to marketing and Performing suppression scrubs

    Hi All
    Forgive me if this is in the wrong location. I received the email below from Gamesys affiliates - it looks like more pressure on us affiliates. it is me or is there a slowing noose around our necks?

    look like we must now upload our mailing list to remove certain members?

    I really want to know whats everyone's view on this and what the future holds for us gambling affiliates.


    At Gamesys, we pride ourselves on being recognised for putting the player at the forefront of everything that we do, including by ensuring that our affiliate marketing meets regulatory obligations.

    As you will be aware, all advertisers (including affiliates) have a legal obligation to ensure the content and distribution of marketing is compliant with the CAP Code and data protection legislation.

    The regulatory landscape is constantly developing and we would like to remind you of the importance we place on marketing compliance.

    For further information, we strongly advise you to review the CAP Guidance Note "Online Affiliate Marketing". You can also contact our Affiliate Team.

    1. Updates to Gamesys Affiliates Programme Terms and Conditions

    You will shortly be asked to review and accept updated Gamesys Affiliates Programme terms and conditions. It is important that you read these in full and understand your obligations under them. Below is a summary of some of the new terms to expect, a reminder of some of the terms and conditions you have already signed up to, along with general compliance points you should be aware of and always adhere to when promoting Gamesys products.

    2. Explicit consent to marketing

    Further to data protection regulation, when advertising via email or SMS* all advertisers are required to obtain explicit consent from their data subjects for the type of advertising they are sending out.
    We expect our affiliates to be able to evidence, on demand, dates for which they received consent from a data subject, and the wording of such consent given.

    Gamesys will be terminating affiliate contracts if such affiliates cannot provide such evidence as soon as reasonably practicable and in accordance with our instructions.

    You will be receiving further instructions on this in due course.
    You should ensure that all email and SMS marketing includes a clear ‘unsubscribe’ option for consumers to easily opt-out of receiving future marketing communications, and all communications should state that such marketing comes from the affiliate and not from Gamesys.

    *Please note that until further notice, Gamesys does currently not allow its affiliates to send out SMS marketing on its behalf.

    3. Performing suppression scrubs

    You will soon be receiving further communication from us regarding a new requirement for all Gamesys affiliates; for every email send, Gamesys requires (further to gambling regulation) its affiliates to perform a suppression scrub of its marketing lists against a list of data subjects which Gamesys marketing should not be sent to.
    Gamesys is working with an independent third party who will provide this software for Gamesys and affiliates to perform this scrub securely, and at no cost to the affiliate. We do not have access to affiliate data and you can upload your data to the platform in a hashed format.

    It is crucial that Affiliates understand that they do not have Gamesys’ approval to send email marketing unless such scrub has been performed for each send.

    Please look out for more information coming soon about how to access this platform.

    4. Clearly identifying marketing

    All marketing should be obviously identifiable as an ad. If you operate a ‘review’ website or otherwise write advertorials for Gamesys products, you are required to ensure that such content is labelled correctly to not mislead consumers.
    All marketing assets are to be signed off by Gamesys in any case.
    In addition, if you promote Gamesys via Social Media channels, all posts / tweets must contain ‘#ad’ in an obvious place.

    5. Including significant conditions

    Significant conditions to promotions (restrictions / conditions on prizes, entering a competition or taking up an offer, for example) must be included in advertising content, with a link to full terms and conditions within one click.

    This requirement is the same for Social Media posts. Please see the example at Appendix 1 of a non-compliant tweet and a compliant tweet.

    Please note, all assets which have been provided for your use on the Gamesys affiliate platform have been pre-approved for marketing compliance by Gamesys. All other assets you wish to use need to be approved in each case.

    6. Targeting over 18s

    As gambling is an age-restricted product, gambling advertising must not be directed at those under the age of 18 and affiliates must be able to demonstrate that they have taken reasonable steps to place or target their ads appropriately. For example, if you promote Gamesys products via social media channels, you should be able to demonstrate that the demographic for such channels are adults and you should include a clear ‘18+’ message on your account(s). You can read more about how you can comply with this requirement here.

    7. Provisions on gambling advertising

    Remember, you are obligated to ensure that all advertising promoting Gamesys brands is compliant with the gambling specific section of the CAP Code. As a reminder, this means that gambling marketing should not:

    • Suggest gambling can be an escape from; take over from; or be indispensable to; personal, professional or financial problems and commitments;
    • Suggest gambling can enhance personal qualities, e.g. self-esteem, or that it is a way to gain control or admiration;
    • Suggest peer pressure to gamble or suggest gambling is a rite of passage;
    • Link gambling to seduction, sexual success or enhanced attractiveness;
    • Portray gambling in a context of toughness or recklessness;
    • Suggest gambling is better enjoyed alone;
    • Be directed at those under 18, be likely to appeal to children or feature anyone who is or appears to be under 25 years old; or
    • Encourage or condone criminal or anti-social behaviour.

  2. #2
    universal4's Avatar
    universal4 is offline Forum Administrator
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    In the end this may reduce gambling spam to a degree, and it is the fault of all who mail to purchased, rented, borrowed or otherwise traded for lists, as well as those lists compiled from any public email lists.

    If the recipient has not specifically asked to be on the list, they should not be receiving the advertising emails.

    I personally would also like to see ALL operators have a clause they mailers can NOT send emails from xxx casino. The form should be clearly identified as the marketer, and should NEVER arrive with the false sender information of the casino's name as the send. This immediately makes all recipients that were not expecting nor wanting the email to immediately blame the operator, not the sender or affiliate.

    The advertising restrictions do look a little strict, and I wonder if as affiliates we may need to start linking any review pages to the bonus terms and conditions pages of the operators advertised on such pages.


    Side Note: I have moved this to one of the more general chatter type forums where it will likely gain more exposure and generate more discussion.

  3. #3
    universal4's Avatar
    universal4 is offline Forum Administrator
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    I just noticed that Michael put up a poll related to this subject here (so I will temporarily lock this thread so the discussion about this important subject can be contained in ONE place.


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