Advertising standards and prohibitions

1) Purpose and area

Establish uniform standards for advertising communication for all markets and channels, eliminating misleading advertising, advertising to minors and vulnerable groups, as well as violations of licensing and advertising rules. Coverage: paid advertising, CRM (e-mail/SMS/push), social networks/influencers/streamers, offline activation/sponsorship, site/application windows, affiliates.

2) Fair-Marketing Principles

1. Truthfulness and verifiability. Any quantitative or qualitative approval is supported by data/conditions.
2. Protecting vulnerable groups. No targeting of underage/self-excluded/players with active RG restrictions.
3. Responsible play. Balanced tone, no pressure, prominent limits/breaks/SE references.
4. Transparent bonuses. Key conditions - before participation (see "Transparency of bonus conditions").
5. Local correspondence. Compliance with the laws and codes of a particular market (age, language, disclaimers, channel bans).
6. Lack of manipulation. Banning dark UX patterns and aggressive "no risk" promises.

3) Roles and RACI

Head of Marketing (Owner) - strategy, budget, comm. policies. (A)

Compliance/Legal - legal expertise, prohibitions/mandatory disclaimers, final approval. (A/R)

RG Lead - compatibility with RG, suppression in vulnerable. (C)

CRM/Performance Leads - plan/creatives/splits/UTM, targeting compliance. (R)

Affiliates Manager - partner control, contractual clauses, audits. (R)

Social/Influencer Lead - briefs and content control of streamers/influencers. (R)

Brand/Creative - creatives and copyrights on the whitelist. (R)

Data/Engineering - suppression flags, log audits, version catalogs. (R)

Internal Audit - independent samples of campaigns, CAPAs. (C)

CS/Trust & Safety - complaints and escalations. (R)

4) Basic prohibitions (applicable to all channels)

• Advertisements addressed to minors or people of unknown age; using youth aesthetics/slang/characters popular with <18/21.
• Any wording: "no risk," "guaranteed gain," "close debts," "easy money."
• Statements about skill/control in games of chance ("you can beat the system").
• Images of financial despair (loans, debts, promise to improve lives).
• Calls to play despite restrictions or "remove limits for the sake of a bonus."
• Hidden bonus conditions or retroactive changes for those already participating.
• Using images of medical/educational institutions, state symbols to create trust.
• Broadcast creatives on sites/formats prohibited by the market (for example, outdoor advertising in prohibition zones/time windows).
• Retargeting by audience segments containing vulnerable features (gaming addiction, health, social assistance, etc.).

5) Required Ad Elements

Age disclaimer: 18 + or 21 + (by market), visible.
Responsible game: link/icon to the RG section (limits/break/SE).
Bonuses: summary box with key conditions (WR, max bet, game contribution, deadlines, cap), a single hash of the condition version.
Legal elements of the market: local icons/texts (state warnings, license, prohibition of hour slots, etc.).
Version: creative ID, version, date/time of publication.

6) Targeting and exclusion rules

Age: targeting only 18 +/21 +; unknown age = exclude by default.
RG-suppress: automatic exclusion of players with active SE/timeout/high risk/affordability-check.
Geo/time: forbidden geofences and "watershed" restrictions (night hours) by market.
Affiliates: required to apply the same filters; sending acknowledgement logs.

7) Channel standards

7. 1 Paid advertising (search/social networks/programmatics)

Use only approved wording and creatives (whitelist).
Cabinet settings: age filters, exceptions for "young interests," bans on similar audiences for youth segments.
You cannot write "official website" without a license/confirmation.
For re-engage: exclude players with RG flags and high-risk.

7. 2 CRM (e-mail/SMS/push/in-app)

All mailings are RG-suppressed and checked for local quiet hours.
The promo ignores players during a cooling or active RG case.
Content of letters = landing with the same condition version.

7. 3 Social networks/influencers/streamers

Brief and contract: age restrictions, prohibition of "easy money," honest demonstrations (do not hide losses), tags 18 +/21 +, advertising.

Banning "hype streams" with aggressive calls and a "deposit race."

Any promo code is associated with a version of the terms; there are no unique promises not reflected in the landing.

7. 4 Affiliates

Contractual clauses: age filters, copy summary box, prohibition of "gray" geo/creatives, audit rights, clawback for violations.
Postbacks: transmission of version-hash T&C for each click/registration.
Blacklist: prohibited sites/formats; automatic scanners and review sampling.

7. 5 Offline/Sponsorship

Ban on placement near schools/universities/medical institutions; compliance with local distances and time limits.
Any "family event" scene - no direct calls to play; focus on responsible entertainment 18 +/21 +.

8) Copyright: what you can/can't

9) Pre-flight approval process

1. Brief → Creative → Self-Check (marketing/brand).
2. Compliance/RG Check: Bonuses/Disclaimers/Targeting/Market.
3. Legal Sign-off: local prohibitions/mandatory elements.
4. Versioning & Hash: fix text/pictures/landing pages.
5. Launch with Flags: include suppression and market profiles.
6. Post-launch QA: screenshots did pokazov/UTM↔versiya match.

Any edit = new version; old participants - according to the previous conditions.

10) Data, artifacts and storage

• `ad_id, version, market, channel, audience_filters, creative_hash, terms_hash, published_at, owner, approvals{marketing, compliance, legal}, rg_suppress_applied, placement_urls[], influencer_id/affiliate_id, complaints_link_id`.

Storage in WORM repository, integrity control.
Logs of impressions/clicks with binding to the condition version and targeting parameters.

11) Complaints, incidents and CAPAs

Complaints: registered in the ticket system, SLA response ≤ X business days.
Incidents: immediate shutdown of creative/campaign at risk of harm/disruption; informing management/regulator on market requirements.
CAPA: corrective actions (processes/templates/training), revalidation.
Goodwill: Transparent rules for benevolent settlements.

12) KPI/KRI and dashboard

Complaint Rate (for 1k impressions/letters/clicks).
Regulatory Findings.
Affiliate Consistency (matching creatives/versions and share of violations).
RG Suppression Integrity (% of RG flag players receiving promo = 0).
Version Match Rate (click → offer version ↔ T&C version).
Time-to-Takedown (median shutdown of problem creativity).
False Promise Index.
Influencer Compliance (share of videos with correct marks/18 +/RG).

13) Checklists

A. Creative self-test (marketing/brand)

• Age Disclaimer 18 +/21 +.
• No promises of "no risk," "guaranteed winnings," "easy money."
• Bonus: there is a summary box and a WR example.
• RG links/icons are present.
• Language is neutral, without pressure/dramatization.

B. Pre-flight (Compliance/Legal/RG)

• Geo/time market constraints considered.
• Age/behavioral exceptions are configured.
• T&C version and hash are fixed, UTM is bound.
• The affiliate/influencer received the brief and signed the clauses.
• Monitoring plan and CS contact point are defined.

C. Audit of Affiliates/Influencers

• Screenshots/stream archive, presence of 18 +/RG.
• Matching landing page and version texts.
• No prohibited sites/formats.
• Audience filter logs provided.

14) Templates (quick inserts)

A) Short banner disclaimer

B) Influencer/streamer brief (shutter speed)

Ad tagging and 18 +/21 + in description/frame.
No "no risk "/" easy money "promises.
Showing honest gameplay (including losses).
Prohibition of calls to bypass limits/SE.
Link to the offer with the same version of the conditions.

C) Clause in an affiliate agreement

D) CS Response to Introductory Ad Complaint

15) Technical framework

События: `ad_impression_logged`, `ad_clicked`, `terms_version_resolved`, `rg_suppress_applied`, `ad_complaint_opened`, `ad_takedown_triggered`.
API/features: catalog of approved creatives; auto-insert disclaimers; condition version validation; CRM/Ads suppression; "alarm button" for urgent shutdown.
Monitoring: scanner of external pages of affiliates; comparison of texts with a standard; alerts when retreating.

16) Regional profiles (framework)

Market: ______
Age: 18 +/21 +
Forbidden channels/time windows:...
Required Disclaimers/Icons:...
Bonus restrictions in advertising:...
Regulatory response reporting/timelines:...
Special rules for influencers/offline:...

17) 30-day implementation plan

Week 1

1. Approve the policy and the matrix of prohibitions/mandatory elements by market.
2. Collect a catalog of approved formulations and creatives (whitelist).
3. Configure RG/age-suppression in CRM/Ads.

Week 2

4) Run pre-flight process (Jira/tips), versioning and hash.
5) Sign updated clauses with affiliates/influencers.
6) Turn on the partner page scanner and the urgent shutdown button.

Week 3

7) Pilot on 2-3 campaigns: Complaint Rate/Version Match.
8) Marketing/CS/affiliate team training (1 hour).
9) Retro and copyright/filter adjustments.

Week 4

10) Full release; weekly KPI reports and CAPA list.
11) Affiliate/Influencer Quarterly Audit Plan.
12) Plan v1. 1: regional auto-profiling, auto-checking creatives for stop words.

18) Interrelated sections

Transparency of bonus conditions

Responsible play and limits/Reality Checks

Self-exclusion and account blocking

Age verification and age filters

Code of Ethics and Conduct

Incident Playbooks and Scripts (Marketing/PR)

Compliance dashboard and monitoring

Regulatory Reports and Data Formats/Audit