Disclaimers and veracity of advertising

1) Purpose and area

Establish uniform rules for fair, verifiable and responsible advertising, ensure correct disclaimers and provability of applications in all channels: paid advertising, CRM, social networks/streams, affiliates, website/applications, offline/events. The document complements the sections "Advertising standards and prohibitions" and "Transparency of bonus conditions."

2) Fair-marketing principles

1. Truth and verifiability. Any application can be supported by documents/data.

2. Visibility of key conditions. Critical restrictions - before participation, and not in the "footnotes."

3. Clear language. Simple formulations, numerical examples, lack of ambiguity.
4. No masking of risk. Disclaimers do not "redeem" the introducing copyright.
5. Unified version. Disclaimer ↔ offer conditions ↔ creative - one version and hash.
6. Protecting the vulnerable. Age markings/filters, references to RG, suppression in SE/high risk.

3) Roles and RACI

Head of Marketing (Owner) - strategy, library of disclaimers. (A)

Compliance/Legal - approval of wording and local mandatory markups. (A/R)

RG Lead - compliance with the responsible game (tone, links, suppression). (C)

Brand/Creative/UX - layout, size/contrast, "summary box." (R)

Performance/CRM - correct insertion into creatives and cabinets, targeting. (R)

Affiliates Manager - compliance with the wording by partners/streamers. (R)

Data/Engineering - version/hash, show logs, link to offers. (R)

Internal Audit - campaign samples, CAPA. (C)

4) Mandatory types of disclaimers (frame)

1. Age: "18 +/21 + (by market)."

2. Responsible game: short link/Limits/Break/SE icon.
3. Bonus summary: WR, max bet, contribution of games, timing, cap of winnings, payment methods/exclusions.

4. Time/quantity limits: "only until [date]," "first N customers," "up to € X."

5. Legal local: license/mandatory inscriptions/icons (by market).

6. Conflict of interest/advertising: for influencers "# ad/paid placement."

7. Technical limitations/availability: "only in [geo/device list]" if applicable.

5) Format and placement (UX standard)

Size/contrast: at least 90% of the main text on the banner; contrast of WCAG AA +.
Location: in the first screen (above the fold) or in creativity; for video - in frame ≥ 3 sec + in description.
Links: clickable, lead to the offer card with the same version of the conditions.
Language: local, no jargon; "micro-rifts" and fast-disappearing clues are banned.

Mobile format: adaptability, do not hide behind "more."

6) Truthfulness of statements (claims): rules

6. 1 Quantitative

Specify comparison base and method (e.g. "WR 30 bonus ×").

Examples are required: "€100 bonus ⇒ €3,000 to play."

"Up to € X" - real reachability; the illusion of warranty is prohibited.

6. 2 Quality

"Best," "No. 1," "fastest" - only with fresh and comparable confirmation (method/period).
The statements "no risk," "easy money," "guaranteed winnings" are prohibited.

6. 3 Comparative advertising

Only verifiable metrics, identical test conditions, reference to methodology.
Without discredit and distortion (including selective periods).

6. 4 Social Evidence and Feedback

Mark "advertising/partnership"; prohibition of fake reviews.
Screenshots of winnings - without promises of repeatability; personal data blur.

7) Confirmation procedure (substantiation)

1. Brief: List all potential creative claims.
2. Evidence: BI data, provider reports, test methods, screenshots of offices, legal documents.
3. Compliance/Legal Review: Market Fit, Disclaimer Language.
4. Versioning: 'creative _ hash', 'terms _ hash', published date.
5. Archive: keep a package of evidence for at least the term of retention (usually 5-7 years).

8) Channel standards

8. 1 Paid advertising (search/social/programming)

Auto-insert 18 +/RG and short bonus disclaimer into templates.
Character restriction: key conditions - in the "short version" without shortening the meaning.
Screenshots of impressions/settings are stored with 'creative _ hash'.

8. 2 CRM (e-mail/SMS/push/in-app)

The same text of the disclaimers as on the landing; suppression для SE/RG/unknown age.
Avoid ambiguous promises in the subject/pre-header.

8. 3 Social networks/influencers/streams

In the frame: 18 + and RG; in the description - disclaimer + link to the offer version.
The mark "advertising" is mandatory; showing honest gameplay (including losses).

8. 4 Affiliates

Use only our whitelist of formulations and disclaimers (terms_hash).
Must transfer version-hash to postback/UTM; no edits.

8. 5 Offline

Layouts with 18 +/RG and key conditions are readable from a distance; legal market badges.

9) "Summary box" for bonuses (minimum)

Bonus type/size; WR and WR base with an example; the contribution of games; timing; max bet at WR; cap winnings; excluded games; Payment methods/exclusions condition version and date.
Block - above CTA; without it, startup is prohibited.

10) Data, versions and storage

ad_id, creative_hash, terms_hash, market, channel, locale,
disclaimers{age, rg, bonus_short, legal_local, time_limit},
claims[], substantiation_docs[], approvals{marketing, compliance, legal},
published_at, takedown_at, owner, screenshots[], placements[],
rg_suppress_applied, affiliate_id/influencer_id

WORM artifact storage; connection with the offer and reports.

11) KPI/KRI and dashboard

Version Match Rate (click → match the condition version).
Complaint Rate (for 1k impressions/letters) and the share of complaints about "introductory" wording.
Auditability Score (% creatives with full evidence package).
Takedown Time (median shutdown of problem creativity).
Affiliate/Influencer Compliance (match of disclaimers and terms_hash).
False Promise Index.
RG Suppression Integrity (% vulnerable who received promo = 0).

12) Checklists

A) Creative self-test (marketing/brand)

• 18 +/21 + and RG are noticeable; contrast AA +.
• Key constraints in summary box, not footnote.

• Bonus disclaimer brief and honest; there is an example of WR.
• The link refers to the same condition version.

• All claims are listed and confirmed.
• Local legal markups/icons added.
• age/RG-suppression are included in targeting.
• 'creative _ hash' and 'terms _ hash' are fixed.

• Screenshots of impressions/settings saved.
• Monitoring complaints and stopwords.
• Affiliates/streamers comply with the wording.

[There is no "no risk," "guaranteed," "easy money."

B) Pre-flight (Compliance/Legal)


C) Post-startup


13) Templates (quick inserts)

A) Short banner disclaimer

> 18+/21+. Play responsibly: Limits/Break/SE. Bonus: WR 30 × bonus, max bet €5 at WR, 14 days wagering. Details on the offer page.

B) Disclaimer "up to €/time"

> Up to €200. Valid until 15. 12, for the first 5,000 participants. Bonus terms apply.

C) Description below video/stream

key> Ads (Paid). 18+/21+. Play responsibly: Limits/Break/SE. Bonus: WR 30 × bonus, max bet €5, term 14 days. Conditions v1. 8 (link).

D) CS response to small print complaint

> Key conditions are indicated in the initial screen and in the "summary box" (vX version. Y). We apologize and stand ready to clarify any clause as well as propose a settlement.

14) Incidents and CAPAs

Signal: complaint/scanner/audit → immediate takedown at risk of harm.
Investigation: Verification of the version, verification of claims and evidence.
Solution: editing the wording/calculation, training the team, updating the library of disclaimers.
CAPA: pre-flight process adjustments, stop phrases in linters, mandatory fields in the brief.

15) Risks and prevention

Disclaimer "hides" the truth. → Transfer to the "summary box," explicit numbers and examples.
The affiliate has a version mismatch. → terms_hash in UTM/postback, right to clawback.
"No. 1/best" without evidence. → prohibition until the method is provided.
Non-obvious sar/exceptions. → explicit lines in the short card of the offer.
Mobile "microcrift." → size ≥ 90% of the main text, test on a real device.

16) 30-day implementation plan

Week 1

1. Approve the library of standard disclaimers (RU/EN + key locales).
2. Describe the list of acceptable claims and evidentiary requirements.
3. Implement a "summary box" template for all bonuses.

Week 2
4) Implement version/hash and autofield disclaimers in CMS/Ads templates.
5) Connect stop phrase linter and pre-flight checklist in Jira.
6) Train marketing/CRM/affiliate team (1 hour).

Week 3
7) Pilot on 2-3 campaigns; замер Complaint Rate/Version Match/Takedown Time.
8) Audit of 10 affiliate landings/2 streams; reconciliation of formulations and hashes.

Week 4
9) Full release; weekly KPI report and CAPA register.
10) Update contract clauses with affiliates/influencers.
11) Plan v1. 1: autogeneration of a short disclaimer from the offer scheme; ML alert to "questionable" claims.

17) Related Sections

Advertising standards and prohibitions
Transparency of bonus conditions
Compliance of affiliates and partners
Age verification and age filters
Responsible play and limits/Reality Checks/Self-exclusion
Incident Playbooks (Marketing/PR)
Compliance Dashboard and Monitoring/Internal and External Audit