A website offering prices for windows and doors, www.windowsanddoorsprices.co.uk, included the following claims on the home page: "You could be comparing prices in LESS THAN A MINUTE"; "The UK's No. 1 Windows & Doors Price Comparison Website!"; "How it works ...1. Enter your details 2. We provide you with prices from trusted companies 3. You compare and get the best possible prices"; and "Why Compare Prices? We can offer a huge saving of up to 75% off windows, doors and conservatories You can compare up to 5 prices provided by trusted local companies Our service is completely free and you have no obligation to buy anything Avoid rogue and cowboy tradesmen as we stringently vet all companies It only takes 20 seconds to start comparing prices online".
The complainant, who understood the advertiser forwarded customers' details to window and door companies rather than providing quotes a consumer could compare, challenged whether the claims they offered a price comparison service were misleading.
Windows and Doors Prices UK Ltd t/a Windowsanddoorsprices.co.uk (Windows and Doors Prices UK) said they believed that for the majority of their customers the message from their website was accurate and appropriate. They said they were a lead generation affiliate website. They did not deliver the work for customers, but passed details submitted on to windows companies and networks of companies. They said they had coverage across the UK which meant that most customers got windows quotes from three to five contractors, but in some postcodes they were partnered with fewer contractors meaning they might only receive one or two quotes. They said that in a small number of cases they might only receive one quote, from a national supplier. They said their reference to "20 seconds to start comparing prices" referred to the time it took to complete the form.
The ASA considered that the ad, and in particular the references to price comparisons and that you could compare prices in "less than a minute" and "20 seconds", implied that by filling in the web form consumers would be served with a number of prices online which they could then compare. However, we understood that Windows and Doors Prices UK passed on the details submitted to their partner companies, who would then contact the customer with a quote. We considered that this was likely to affect a consumer's decision to fill in the web form and provide their details, and that the website should have accurately described the service that they offered. We therefore concluded the ad and claims referring to a price comparison service were misleading.
The ad breached CAP Code (Edition 12) rule
Marketing communications must not materially mislead or be likely to do so.
Marketing communications must not mislead the consumer by omitting material information. They must not mislead by hiding material information or presenting it in an unclear, unintelligible, ambiguous or untimely manner.
Material information is information that the consumer needs to make informed decisions in relation to a product. Whether the omission or presentation of material information is likely to mislead the consumer depends on the context, the medium and, if the medium of the marketing communication is constrained by time or space, the measures that the marketer takes to make that information available to the consumer by other means. (Misleading advertising) and 3.9 3.9 Marketing communications must state significant limitations and qualifications. Qualifications may clarify but must not contradict the claims that they qualify. (Qualification).
The ad must not appear again in its current form. We told Windows and Doors Prices UK to ensure that the description of the service they offered did not mislead and to make clear that customer's personal details would be passed on to their partner companies.