Pelaanyt' Marketing Communications Responsibility Principles

Pelaanyt' operations include corporate social responsibility as an essential component of its business. The core of our operations is responsible gaming and marketing.

We believe that responsible and sustainable business practices are vital to our mission. Our marketing is guided by principles that ensure games and gambling are promoted in a sustainable and responsible manner while maintaining the company's commitment to responsibility.

These principles are a fundamental part of our operations and strictly adhere to the regulatory framework that governs our company's strategy. Marketing serves not only promotional purposes but aims to direct Finnish gambling to our regulated and supervised gaming environment. Marketing is not targeted at minors. Our company only provides product and game information about games with a particular risk of harm. These principles also include guidelines on responsible sales, game promotion and marketing cooperation.

General Principles

1. The purpose of Pelaanyt' marketing is to strengthen our brand, promote supervised and responsible gaming, and raise awareness about harmful effects. Our marketing aims to contribute to achieving our responsible gaming objectives through transparent communication. The focus of communication for games with higher risk (so-called red games) is providing consumers with comprehensive product information necessary for informed gaming decisions. This information does not encourage gaming nor is otherwise exaggerated. In Pelaanyt' own special gaming venues, Pelaanyt may promote games that are available to play in the gaming hall in question. In Pelaanyt' digital services, marketing of games that are available to play in the service in question can be carried out beyond the game itself.

2. All our marketing communications respect the individual and protect consumer freedom of choice. Our marketing communications do not portray excessive gambling positively or stigmatize non-gambling or moderate gambling behaviors.

3. Pelaanyt' marketing does not address everyday gambling. Gambling is not discussed as part of everyday life and is not equated with, for example, the purchase of food or clothing.

4. Pelaanyt' marketing does not abuse consumers' trust in the gaming industry or gaming operators and does not take advantage of consumers' inexperience or lack of information.

5. Pelaanyt' marketing does not encourage discrimination based on national origin, religion, gender, or age, nor does it violate human dignity.

6. Pelaanyt' marketing does not make false claims or use harmful stereotypes of general situations.

7. Pelaanyt' game marketing does not provide false information or a misleading picture of the consumer's actual chances of winning. Winning is based on chance.

8. Marketing does not utilize methods that, when assessed as a whole, can be considered aggressive or deceptive. Accordingly, the following measures are refrained from in the sale and marketing of Pelaanyt games:

a. Pelaanyt does not give its customers free games or play money (excluding situations involving game testing or similar measures).

b. Pelaanyt does not sell its games at a discount or in a manner that could be construed as giving discounts or offers (the above does not apply to additional raffles or games in accordance with Pelaanyt' game rules).

c. Pelaanyt does not offer or allow its agents to offer freebies related to its games, nor does it tie its own games as freebies for other products.

d. Pelaanyt's game marketing does not encourage the funding of charitable activities through gaming. Pelaanyt' beneficiaries and the distribution of Pelaanyt's revenue may be communicated, but not in connection with game marketing.

e. Pelaanyt does not use marketing lotteries to encourage customers to play or learn about the games.

9. Pelaanyt does not use its marketing to entice consumers into gambling that could endanger the consumer's financial status, health or family relationships.

10. Pelaanyt' marketing does not imply that gambling can be risk-free. Nor does marketing present gambling as an alternative to work or a solution to financial problems.

11. In marketing Pelaanyt' games and services, the aim is to avoid an environment in which there is marketing of quick-fix companies, violent entertainment and sexual services.

12. All marketing must be identifiable as marketing. Pelaanyt does not implement measures that can be interpreted as hidden marketing.

13. Pelaanyt respects the privacy of its customers and ensures the protection of personal data. The customer is informed of the details related to the processing of personal data. Pelaanyt does not maintain, collect or use customers' personal data without lawful grounds.

14. Pelaanyt respects the diversity of people and strives to serve its customers in an accessible manner and does its best to ensure that the physical environment is suitable for everyone at events organized by Pelaanyt.

Protection of Minors

15. The age limit for Pelaanyt games and customer service is 18 years. Pelaanyt strives to include an 18+ sign or a mention of the age limit in its visual marketing.

16. The marketing of Pelaanyt games is not targeted at minors. Pelaanyt only selects media, meeting points or HR sectors whose audience, as researched or otherwise reliably determined, is at least 70% adults. All Pelaanyt social media accounts include a mention of the age limit of 18.

17. Images related to gaming and marketing gaming activities always use people who are at least 18 years old and people who also appear to be of legal age. People under 18 years old are also not used in Pelaanyt's marketing and communications about revenue sharing. However, Pelaanyt may inform about the beneficiaries of its revenue share in its communications without specifically advertising gambling, if minors are not the focus of marketing or communications or the main part of the content.

Sales and Promotion

18. Pelaanyt acts responsibly in its customer communications and sales and complies with generally accepted principles of honest direct marketing.

19. Pelaanyt does not disclose the personal data of the Loyalty Customer to third parties for their own marketing purposes.

20. Pelaanyt strives to offer its customers the best possible service experience by personalizing its marketing. Personalization (and marketing targeting) takes place in a manner informed in the privacy policy in compliance with legislation.

21. Customers who have placed a bet are excluded from our digital marketing communications whenever it is technically possible.

22. Pelaanyt does not have misleading sales promotions. The advertising material used at points of sale, fairs and events, as well as marketing communications, provides correct and relevant information about gambling and the gambling system. External partners and event partners also commit to this.

23. As a rule, all Loyalty Customers can participate in the draws of Pelaanyt Loyalty Customer Programme. Playing or not playing does not affect participation in the draws.

24. Pelaanyt requires that agents, retailers, and anyone else involved in the promotion of Pelaanyt' games or services do not act in a way that undermines consumers' trust in Pelaanyt.

25. In customer service situations, you must always act tactfully so that the customer does not feel pressured. We do not actively peddle games and encouraging people to play is always prohibited.

Marketing Cooperation

26. Pelaanyt' marketing cooperation complies with the law and good practice and complies with generally accepted principles of fair play and honesty.

27. Pelaanyt' marketing cooperation is always based on the obligations agreed upon between the parties.

28. When choosing partners, Pelaanyt pays special attention to the partner's responsible actions and reputation.

29. Pelaanyt includes clauses regarding possible fraudulent activities and/or doping violations in all its marketing cooperation agreements. They allow for immediate withdrawal from cooperation, based on discretion, if Pelaanyt believes that the actions have been fraudulent, contrary to good practice and taste, or fate.

30. All marketing must be clearly identifiable as Pelaanyt' marketing or content. We do not engage in any cooperation with partners that could be perceived as hidden marketing. All content implemented in cooperation has been reviewed in advance and approved in writing by Pelaanyt.

Partner Cooperation

31. Self-marketing of products at points of sale is not permitted. The promotional material displayed at points of sale is produced by Pelaanyt.

32. All game sellers at points of sale must complete Pelaanyt training, which includes responsible game sales.

33. Pelaanyt also requires its advertising and media agencies to acknowledge and practice a high level of responsibility in implementing marketing. An advertising agency or other marketing communications service company must exercise due diligence when preparing marketing communications measures and ensure that both it and Pelaanyt' marketing communications responsibility principles are complied with. To ensure this, every employee of an agency or media agency who works for Pelaanyt must regularly familiarize themselves with these principles. Service providers must familiarize their creative creators with marketing guidelines and responsibility principles.

These principles were updated by Pelaanyt' management team on May 6, 2020.

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