Understanding Ontario’s Online Gambling Plan, Part V: Marketing Considerations

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Ontario online gambling operators will face different marketing challenges than they do in the US. In Canada, online gambling marketers will need to master bilingual content. They will also be limited in discussing bonus offers in their external messaging, as well needing to adjust to Canadian consumers’ brand awareness levels.

On Monday, Ontario’s 15 million residents will gain access to their first regulated online gambling options outside the current Ontario Lottery and Gaming Corporation (OLG) website. As private online gambling operators ready to launch mobile gambling in the Ontario iGaming market on April 4, they’re keeping track of rules, regulations and more subjective matters, like understanding Canadian and Ontarian culture.

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The language issue

Earlier this month, Maine‘s public service announcement campaign urging marijuana users not to drive while high struck an ironic note.

The PSA “Driving High = OUI” refers to “Operating Under the Influence,” yet means “Driving High = YES” to French speakers.

Those francophones comprise nearly 40,000 of the state’s residents, and a far higher percentage of the population of the Canadian provinces of Quebec and New Brunswick, which share the state’s 611-mile border.

Of course, that campaign wasn’t aimed at Canadians. However, it shows why it’s important to remember that Canada has two official languages.

Online gambling operators may or may not market to the 600,000 or so Ontario francophones in their native language.

However, government agencies in Canada are required to use use both official languages. iGO clarified that this does not extend to the private sector companies operating on its behalf, though.

Even so, many Canadian business choose to have French versions of their websites, and at least some online gambling companies may choose to follow suit.

They’ll need to be careful in doing so. Translation gaffes often take quite a while for a new audience to forget. Such a mistake is likely to be the subject of memes, comedy routines or worse.

There are also spelling differences, and contrary to popular belief, Canadian English is not simply identical to British English in this regard. There are also some words that are common in Canada, but not elsewhere. Appropriately enough, that includes “allophone,” which means Canadians whose first language is neither French nor English.

About 2.5% of Ontarians are allophones. The bulk (93.4%) are anglophones, while francophones are a significant minority (4.1%) in the province.

Hiring local translators and copywriters will be important.

Data: Gov. of Canada / Graph: Bonus.com team

No ‘risk-free’ wording or bonus amounts

Operators will need to exercise their brand marketing prowess, because they’re handcuffed in other ways. Commercials running in Ontario can’t offer “risk-free bets” or put dollar values on other promotions – like first deposit or no-deposit bonuses – that are so familiar to US television viewers.

According to the province’s online gambling regulator, Alcohol and Gaming Commission of Ontario (AGCO):

“Advertising and marketing materials that communicate gambling inducements, bonuses and credits are prohibited, except on an operator’s gaming site and through direct advertising and marketing, after receiving active player consent.”

In other words, Ontarians will not see commercials with monetary calls to action. They won’t see those types of offers on billboards, social media sites or following them across the web.

If anyone within the province visits an operator’s site, that will show the marketing and promotion. Also, if an Ontarian opts in to receive messages from online gambling operators, that’s when they will see such marketing and promotion. On a one-on-one basis, online casino players may get “direct messaging via social media, emails, texts and phone calls.”

Such messaging does have an upside of its own, in that it allows for personalization.

No restrictions on ad volume at launch

That said, AGCO considers itself an “outcomes-based regulator.”

What this means it that most of its regulations focus on the result, not the details of execution. Operators will have a lot of discretion in how they achieve those results. However, AGCO will hold them accountable if they fail to do so.

Jay Welbourn, AGCO’s senior manager of technology regulation and compliance, said that AGCO is interested seeing good faith from operators, not in being a prosecutor.

To that end, there won’t be limits placed on the volume of ads, channels or timing, at least at first. That will come if regulators decide it’s necessary, Welbourn said. In the meantime, individual ads will undergo content review by ThinkTV, a company that clears ads on behalf of broadcasters in order to ensure compliance.

Special rules for pre-launch advertising

Pre-launch ads need to include disclaimers to make it clear that the marketplace isn’t operating yet.

This point came from David Smith, iGO’s director of marketing strategy and insights, who gave some examples of acceptable wording:

  • “Coming to Ontario”
  • “Launching in Ontario”
  • “Joining the regulated market in Ontario”

However, these pre-launch ads can’t include the iGO logo, he said.

Additionally, for the first six months, operators will need to present the iGO logo “above the fold.” That is, it needs to be visible to website visitors without scrolling.

Other iGaming Ontario logo requirements for operators include gamblers continuing to use the iGO logo once it moves off of the above-the-fold home page spot six months into launch, he said. Plus, operators need to follow both iGO and AGCO requirements, Smith said.

Lindsay Rennie, iGO’s brand and communications manager, told us on March 9 that operators will also have to include the logo on social media and in their ads “so players know they are regulated.”

He added that “iGaming operators will need to comply” with the marketing and advertising guide in AGCO’s Registrar’s Standards for Internet Gaming. This includes making sure that non-Ontarians seeing the ads understand that the sites are only available within Ontario.

Rennie said Ontario’s online gambling operators will also need to adhere to “any requirements found in its executed operating agreement with iGaming Ontario, plus any associated policies.”

Canadians may see more TV ads than Americans do

When companies or their products are new to consumers, they spend a lot of money on a type of marketing called “brand awareness.”

In the US, online gambling operators who are trying to gain customers when new states launch legal online casinos often refer to this stage of marketing as a “cash burn.”

They’re not joking. Operators tend to spend so much money on television commercials, social media ads and other customer acquisition costs that they don’t expect to turn a profit in new markets for at least a couple of years.

For example, the online sports betting operator with the largest market share in America is FanDuel. Its owner, Flutter, was pleased to report that it was the first major US brand to achieve profitability. Even so, it was merely $14 million in the black in 2021. That’s a small number considering it earned – and spent – over $1 billion in revenue. Its online sportsbook has been operating in the US since 2018.

Meanwhile, a common refrain among Americans is that they’re sick of seeing ubiquitous online gambling marketing ads. At the same time, the ads work. About 25.5 million more Americans bet online last year than did so in 2018, according to research being released this month by the National Council on Problem Gambling (NCPG).

Gray market operators are already here

All of the spending mentioned above is in the context of US markets. There, online gambling operators have been launching their apps almost simultaneously.

In Ontario, many offshore iGaming operators have had a head-start. That may mean US brands and others just starting out in the province will have to spend more money, just to be on an even playing field.

As it stands, Canadian airwaves are full of “dot-net” advertising for international brands, like PartyCasino and LeoVegas. The brands are advertising their .net sites, which are for play money only. They keep these separate from their real-money .com sites. Doing so allows them to skirt the rules against unregulated gambling ads, because the products they’re advertising aren’t technically gambling.

Ontarians already bet between $500 and $700 million a year through these unregulated online gambling operators. Many of these gray market (or “grey,” in Canadian English) brands will be joining the regulated market. Even after April 4, their dot-net ads will remain legal, said Paul Burns, president and CEO of the Canadian Gaming Association (CGA). He said during the IAB webinar on Mar. 7 that the CGA will continue to monitor that situation.

In general, Canadians haven’t yet seen US and European brands create visible marketing campaigns.

On the Ides of March, BetMGM began running its “coming soon” commercials on Rogers Media. The ads feature Ontario native and hockey great Wayne Gretzky, who is also working with DraftKings in Canada on its NFTs.

At the same time, one of the advantages FanDuel had for visibility in Ontario was its daily fantasy sports (DFS) product. FanDuel DFS will shut down in the province on Friday, because the new market is ring-fenced and there wouldn’t be a large enough player pool.

DraftKings, too, closed down its DFS product in Ontario.

In the US, DFS operators like DraftKings and FanDuel use those customer databases to cross-promote real-money gambling products to these free-to-play app customers in newly legal online gambling states. However, Ontario regulators say that marketing there needs to be to active customers.

Raymond Kahnert, a member of the AGCO Communications Team, said on March 31 that operators can’t use databases from DFS or other shuttered products to market new products:

“To clarify, for the marketing and advertising of bonuses, credits or inducements, the operator must obtain active player consent for the site offering the bonus, credit or inducement.

“This means consent cannot be implied based on consent provided on a different or third-party site, or prior to the opening of the market.”

Will Ontarians prefer to ‘bet Canadian’?

One final challenge facing US brands is that some of their competitors will enjoy home field advantage.

One operator entering the Ontario iGaming market, NorthStar Gaming, is arriving with brand recognition that’s only barely younger than the country itself. NorthStar is a subsidiary of the Canadian media company Torstar, which also owns the Toronto Star.

The Toronto Star, Canada’s largest daily newspaper, began circulating in 1892, just 25 years after Confederation.

With this built-in brand awareness and content marketing outlet, NorthStar may not have to spend as much on marketing as other operators.

Another homegrown brand, theScore Bet, has a similar advantage. It emanates from a media company, Score Media and Gaming. It’s active in the US, operating a sportsbook in Colorado, Indiana, Iowa and New Jersey. Even so, Canadians will probably consider theScore to be a local brand. The company’s history began in Toronto, in 1997, with the launch of a sports news app.

While not headquartered in Ontario, Vancouver-based FansUnite Entertainment is a countryman.

On the other hand, US online casino operators with a retail casino presence in or near Ontario may be at less of a disadvantage. These brands are likely to be familiar to Ontarians:

  • Caesars Sportsbook and Casino is the online product of Las Vegas-based Caesars Entertainment. The Caesars Windsor retail casino opened in 1998.
  • Mohegan Gaming and Entertainment (MGE) operates two land-based casinos in Ontario. Connecticut-based MGE is the OLG’s service provider for Fallsview Casino Resort and Casino Niagara in Niagara Falls.
  • BetMGM, a joint venture between Entain and MGM Resorts International, is represented by MGM Grand Detroit. That casino is just across the Detroit River from Windsor.

Continue reading

Previous Article: Part IV – The Revenue Question
Next Article: Part VI – Legal Challenges

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About the Author

Heather Fletcher

Heather Fletcher is the lead writer at Bonus, concentrating on online casino coverage. She had her first published byline at age 10, but didn't get paid for her writing until she got her first newspaper job. Fletcher's newspaper career started at Suburban News Publications in Ohio and eventually took her to The New York Times, where she's still a contract freelance reporter for the National Desk. She covers breaking news from Philadelphia, as needed. In March 2021, Fletcher began writing about online casino gambling as the lead writer for Online Poker Report.

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