The Registrar has established guidelines giving licensees and Operators of bingo halls a wide variety of options for bingo advertising and promotion. Allowable bingo advertising and promotions activities include:
Licensees and Operators are responsible for ensuring that they comply with the Registrar’s policies, the Criminal Code (Canada), the Gaming Control Act, 1992 and Regulations and any other applicable municipal, provincial and federal legislation. Licensees and Operators may contact the AGCO for clarification on AGCO policies.
Licensees may choose to advertise and promote their events:
Licensees that choose to market their events together and/or in conjunction with an Operator of a bingo hall must develop a joint marketing plan, as outlined in “9.7.4”.
The content of all bingo advertising and promotion, including graphics, must comply with the policies outlined in “3.3.2. Advertising Content guidelines”, and the policies listed below:
» the name of the eligible charitable organization conducting the event, and
» the lottery licence number(s).
The licensees in an HCA may decide to market their events together or in conjunction with the Operator of the bingo hall. Each licensee who wishes to participate must consent in writing to the marketing plan. Licensees may develop only one joint marketing plan per hall. A licensee may choose to opt out of the joint marketing plan and conduct its own advertising and promotion.
The licensees must develop a joint marketing plan through the HCA. If the Operator is sharing the cost of the plan, the Operator will be involved in the development of the plan as well.
The joint marketing plan must outline:
Joint advertising costs must be shared between the HCA and the Operator on a 60/40 (HCA/ Operator) basis. The licensee or HCA must contribute its 60 per cent from the up to two (2) per cent it is allowed to spend for advertising. The two (2) per cent must cover the total amount of a licensee’s advertising and promotional activity, including amounts spent independently or jointly.
See “9.7.5. Setting aside funds for advertising and promotion” for further information.
Licensees may set aside an amount of up to two (2) per cent of the Regular Bingo and Table Board Bingo prize board for advertising and promotion activities and up to two (2) per cent of the actual prizes awarded from their Super Jackpot, Progressive Bingo Game and Loonie Progressive Game events.
Members of the HCA who are participating in the joint marketing plan as described in 9.7.4 must submit the agreed upon amounts to the HCA.
Licensees who participate in joint advertising may also conduct their own independent advertising plan, provided they have funds remaining within the allowable limits.
No limit has been set on the amount an Operator of a bingo hall can spend on its own independent advertising and promotional activities.
When an Operator is participating in joint advertising and/or promotion with an HCA, the Operator’s contribution is limited to 40 per cent of the entire cost of the activities.
Licensees who advertise and promote their events independently must deposit funds, up to the prescribed limits, in a separate designated trust account used solely for advertising expenses. Each licensee member of an HCA must submit a report to the HCA outlining:
HCAs must provide member organizations and the Operator of the bingo hall with a quarterly report, including:
At any time, an HCA may return accumulated, unused advertising and promotion funds to the Operator and licensees. The amount returned must be based on the amounts contributed by the individual licensees and the Operator.
Licensees who are carrying out independent advertising and promotion activities must submit quarterly reports on these activities to the HCA.
Licensees and Operators may offer giveaways of non-gaming products to customers and prospective customers. The following policies apply to giveaways:
While both Operators and licensees may stage promotional contests, there are some restrictions:
A third party or an Operator may donate prizes to be given away as part of an Operator or licensee- run promotional contest in exchange for promotional consideration only. No other form of payment is permitted. Operators and licensees may not contract with a third party to offer inducements, such as gifts or the chance to receive a gift, to play games of chance. Operators and licensees must ensure that all promotional contests comply with the relevant municipal, provincial and federal legislation.
Operators and/or licensees may establish customer loyalty programs that reward customers for their patronage, based on the frequency of their visits. A “visit” is defined as one session of not less than 1.5 hours. Customers may redeem their accumulated loyalty points for rewards in the form of giveaways of non-gaming products. Customer loyalty points cannot be redeemed for cash.
If customer loyalty programs are part of a joint marketing plan between licensees and the Operator of the bingo hall, the licensees’ share of the costs, including administration and rewards, must fall within the prescribed limits for advertising and promotion.
Customer loyalty programs may be shared across charitable gaming sites, including those belonging to different Operators, and across geographic/municipal boundaries.
If the organization discontinues the program or ceases operation, the program will constitute a liability, based upon points and/or rewards earned by customers. An organization offering a customer loyalty program must be able to fund this liability.
Customer loyalty programs must be pre-approved by the Registrar in writing. Licensees and/or Operators must submit a detailed proposal containing:
Licensees and Operators may use customer tracking systems to record the information necessary to operate their customer loyalty programs. The tracking system may be as simple as punch cards or as sophisticated as electronic cards. In most cases, the suppliers of the customer tracking systems will not be required to register under the Gaming Control Act, 1992. However, the Registrar may require that a supplier be registered under the Act in order to contract with an Operator and/or licensee to track points or guarantee liability.
The Registrar will make registration decisions on a case-by-case basis, prior to granting program approval. Also, at any time the Registrar may require that a supplier be registered.
Licensees and Operators may use direct mail advertising to communicate with existing customers only. The mail must be addressed to the intended recipient. The licensees/ Operator must compile a formal mailing list of the names and addresses of actual customers at that bingo hall. The list must be available for inspection by the licensing authority.
Licensees and Operators may sell gift certificates or offer them as promotional items. These gift certificates may only be redeemable for cash or non-gaming products. Each gift certificate must state its restrictions, such as what it may be redeemed for, when it may be used and its expiry date. The cost of a gift certificate must be the same as its redemption value.
Gift certificates produced by a licensee may only be sold during that licensee’s events. This must be stated on the certificate.
As gift certificates are the equivalent of cash, they represent a liability for the issuing organization. Licensees and Operators must:
Licensees and Operators who intend to sell gift certificates must develop a policy outlining:
While the Registrar does not have to approve the policy or the accounting measures in advance, the licensee or Operator must be able to provide them for inspection or audit purposes.
The Registrar permits three types of advertising outside the bingo hall:
For advertising that contains both event-specific and non–event specific advertising, a licensee or an HCA may share the cost with an Operator of a bingo hall. Such advertising may contain, for example, information about specific games to be played and general information about the hall, including promotional activities.
When licensees or HCAs and Operators wish to engage in such joint advertising, they must develop a joint marketing plan, as outlined in Section 9.7.4. and make it available upon request by a licensing authority.
Operators and licensees/HCAs may engage in non–event specific advertising, either jointly or independently.
Only licensees, either individually or through a HCA, may engage in event-specific only advertising.
Third parties (parties other than licensees or Operators) may not financially contribute to advertising outside the hall, but they may provide promotional considerations in return for advertising. For example, a company may provide a product giveaway that goes directly to players, in return for being mentioned in an advertisement.
If a third party sponsor is mentioned in an advertisement containing event-specific information, the licensee’s name must be featured more prominently than that of the third party sponsor.
Operators may offer advertising space within the hall to third party sponsors only in return for promotional considerations that go directly to players. Operators may not sell advertising space.