A daily deals website seen on 20 September was headlined "Hair Loss Treatment Voucher". A sub-heading stated "£99 for a £1000 voucher towards any hair loss treatment at Foley Court … save 90%".
A bullet point under the headline stated "Highlights" and further text stated "Use your voucher towards treatments such as laser hair therapy, FUE hair transplant or hair loss hair extensions". Another bullet point stated "Get your confidence back!". Text in the main body of the ad, under the heading "Full details" stated "You'll start by having a consultation with a professional hair consultant to discuss your suitability and needs … offering procedures such as laser hair therapy, FUE hair transplant and hair loss hair extensions, there's bound to be something to help you get your confidence back!".
The complainant challenged whether advertising a hair transplant procedure on a time limited deal was irresponsible.
Wowcher Ltd (Wowcher) said the voucher was available to purchase for a period of four days and that upon purchase, the voucher provided a period of three months for an initial consultation to take place, with a further three-month period in which to make and attend an appointment for treatment. An individual had up to six months to use their credit and to decide whether they wished to then proceed with a treatment. They said that on this particular promotion, individuals were not committed to receiving treatment and the cancellation policy allowed the individual to cancel up to 24 hours before the consultation or appointment, and a refund would be available, if requested, if they decided not to proceed. They stated that this refund policy would be made clear if the ad was repeated in the future. With regard to the treatment itself they said that individuals received medical advice and that each treatment included a consultation with a professional hair consultant which was specifically tailored. They said if an individual decided, post consultation, that they did not wish to proceed with treatment, they would be able to receive a full refund of the price paid for the voucher. They stated that the voucher could be redeemed for £1,000 credit towards a variety of hair loss treatments, alongside the FUE hair transplant procedure including hair loss hair extensions and other non-surgical hair loss solutions. They said that all procedures were carried out by professional hair consultants and were fully explained during consultations. They stated that the ad also contained a link to the website of the company who offered the service so that the individual could obtain further information about the treatments available, prior to purchase.
The ASA noted the voucher related to a variety of hair loss procedures, most of which were non-surgical and therefore participation was unlikely to require such careful consideration. However, the FUE treatment towards which the vouchers could be used was surgical in nature and therefore something that was likely to need careful consideration on behalf of the participant. We noted the voucher could be used towards the FUE treatment but because of the price of the procedure could not be used to buy it outright and that individuals who were considering the surgical procedure would need to also invest a significant amount of their own money. We therefore considered that the offer was unlikely to incentivise individuals who had not already given significant thought to investing in such a procedure.
Individuals who purchased the voucher were not financially committed to the procedure from the outset and a consultation was available immediately after purchase and, if customers then considered that none of the procedures were suitable, they could obtain a full refund. A consultation was also available to individuals prior to purchase of the voucher. Whilst the ads did require a speedy response to take advantage of the vouchers, we did not consider that they would encourage consumers to commit to a cosmetic procedure without the appropriate personal, financial and medical consideration. We therefore concluded that the ad was not irresponsible.
We investigated the ad under CAP Code (Edition 12) rule 1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society. (Social responsibility) but did not find it in breach.
No further action necessary.