We kindly request that you visit this section regularly as we look to keep all of our partners up to date with the latest additions and amendments to the advertising obligations at Sun Bets Affiliates.
Tabcorp UK Limited t/a SunBets (Sun Bets) is firmly committed to working with affiliates to promote and market our gambling products. We view affiliate marketing as a key component in our business model and we view our partnership as part of our continued growth story. This is reflected by our fair Terms & Conditions, superior tracking and reporting, and publicly available gross to net revenue deductions.
However, we are conscious that marketing activity undertaken by our affiliates could put us at risk of financial sanctions, serious damage to our reputation or, in the most extreme cases, revocation of our operating licence.
As such, we would like to make you aware of the following procedures, which you must follow, whenever you carry out marketing activity on our behalf:
• Gambling advertising must be undertaking in a socially responsible manner and in compliance with the CAP and BCAP Codes issued by the ASA. For further information, see:
• Any marketing you undertake for us using social media (e.g. Facebook, Twitter) must use the age-screening function (where applicable) and any direct marketing videos uploaded to YouTube must check the age restriction option when they are uploaded. All social media accounts which are used to promote Sun Bets offers should include a prominent 18+ symbol. For further information, see:
• Advertising should not be intentionally marketed or have “particular appeal” to under 18s. The ASA has recently advised that “particular appeal” would include use of advertising which includes colourful and exaggerated carton-style graphics……cartoon animals or characters from children’s TV, nursery rhymes, and fairy tales. You must not use these types of images to promote Sun Bets products. For further information, see:
• We require you to include an 18+ symbol whenever promoting Sun Bets as it is a criminal offence to invite a person under 18 to gamble. Marketing communications must not include a child or young person (under 18). No person who is, or looks under 25 may be featured gambling or playing a significant role in any marketing communications. Under 25s must not feature in social media.
• Marketing communications, particularly those for free bets and bonus promotions must not mislead. Significant conditions or limitations of Sun Bets promotions must be prominently displayed in the main body of your adverts. These could include eligibility restrictions, deposit and wagering requirements, restricted odds/games and withdrawal limits. If space is limited (e.g. a very small banner advert) then those significant conditions must be accessible no more than one click away on our website.
• Digital adverts must not be placed on websites providing unauthorised access to copyrighted content (e.g. football streaming sites)
• Marketing by phone, e-mail, or text must only be undertaken to a person who has consented to that marketing and for that specific purpose. Consent must be freely given, clear, specific and informed and proof of such consent is required to be recorded and maintained. As you will be aware, data protection regulation across Europe is changing and the General Data Protection Regulation will come into force on 25 May 2018. This will, amongst other things, increase the threshold for consent which is required to process personal data and use such data for marketing purposes.
• Under the Gambling Commission’s Licence Codes and Conditions of Practice (LCCP), Sun Bets is responsible for the actions of its affiliates and must be able to terminate an agreement with an affiliate promptly, if the affiliate carries out marketing on its behalf in breach of the LCCP, the IGRG Code and/or CAP/BCAP Codes (together the Codes). We would remind you that under the terms of clause 11 of our Affiliate Agreement, should any of your marketing activity not comply, we have the right to immediately terminate our agreement with you.
In practice, we accept that it is not feasible for us to audit all of your advertising material to ensure that it complies with the above requirements. We have tried to set out the significant issues that you should bear in mind when promoting and advertising Sun Bets products and highlight our expectations of you as our affiliate; however, the list above is not exhaustive.
Should you have any specific concerns or questions about anything set out in this letter then you will be able to find further information at the affiliates section of our website at http://sunbetsaffiliates.com or you could contact us by e-mail at firstname.lastname@example.org
It should be noted that nothing in this section of the website, or in any emails or other correspondence from us constitutes legal advice and the information contained therein is not exhaustive.
We recommend that you seek independent legal advice to ensure that your advertising material is compliant with the Codes and that you are compliant with existing data protection legislation. May we also take this opportunity to highlight that we will assume that you are undertaking audits of your data protection processes and the personal data that you currently hold in preparation for the change in legislation from May 2018.