Household

A Facebook post promoting the Arlo Ultra 2 included the following wording:

“Save 20% on Ultra 2 multi-cam and get a FREE Video Doorbell kits with ULTRA20”
“The First. Still The Best. Unmatched 4K security, 10 years in the making. Save 20% Code ULTRA20”

The advertisement also included “10 years of Perfecting Home Security”

The complainant objected to the advertising on the following grounds.

Issue 1:
The complainant considered the advertising of a discount code of 20% was misleading as it did not work when they attempted to use it.

Issue 2:
The complainant considered that the claim “10 years of perfecting home security” implied that the product, a camera kit and doorbell, were a security system. They considered this misleading as a security system had the ability to protect a physical property from unauthorised access, theft or damage, whereas they considered a camera kit and doorbell were likened to CCTV.

Issue 3:
The complainant considered the claim “10 years of perfecting home security” was misleading as they believed that the advertiser introduced their security system in 2022.
They said that the product advertised was introduced in 2020, whereas the doorbell was introduced in 2023.

Issue 4:
The complainant considered that the claim “4K Security” was misleading as the advertising did not notify users that recordings in 4K were only available with a subscription.

Issue 5:
The complainant considered the claim “Unmatched” in the claim “unmatched 4k Security” was misleading as they considered that there were a number of other systems on the market that offered 4k recording.

Issue 6:
The complainant considered that the word ‘perfecting’ in the claim “10 years perfecting home security” implied that the system advertised was faultless when they had experienced issues with the system they had purchased.

The advertisers responded to the issues raised.

Issue 1:
The advertisers said that a temporary technical error in their third-party tool prevented the code from working properly in certain cases. As soon as the issue was identified, they took immediate measures with their provider to ensure it was rectified, which was achieved the following day. They said that, importantly, all qualifying customers received the advertised discount.

Issue 2:
The advertisers said that they did not agree with the complainant’s characterisation of their product as ‘CCTV’. They said that their products were marketed as “home security solutions” intended to be used independently by end-users for protecting their home. They enabled customers to monitor potential risks at their home in real time, without the need for professional installation or a centralised monitoring service. They said that, unlike traditional CCTV or continuous surveillance systems, which were typically associated with third-party monitoring, institutional settings, or large-scale surveillance, their devices were standalone security products accessible to individual households. They said that they empowered consumers to directly manage their own home security through an application. Accordingly, they considered their reference to “home security” was accurate and consistent with the practical function and purpose of the products they provided, which extended well beyond mere video recording.

Issue 3:
The advertisers said that the claim in question referred to brand and overall expertise, rather than to any specific product. They said that Arlo Technologies was founded in 2014 and introduced the wireless, high definition, outdoor ready Wi-Fi security camera with night vision and battery power. They said they used the 10-year mark across their content and creatives to point out the brand’s commitment to constant progress and development since Arlo was established 10 years ago and the first camera was introduced and they provided the Executive screenshots of the claim being used in other campaigns.

Issue 4:
The advertisers said that the complainant appeared to have misunderstood their offer by alleging that 4K resolution was only available with a subscription and that this was not specified in the advert. They said that this was not the case as their “Arlo Ultra cameras” provided 4K resolution for both live streaming and local storage (as they were sold with a “Smart Hub” allowing local storage), hence without subscribing to any additional services. They said that the subscription service only allowed the possibility of 4K cloud storage but did not limit or condition the availability of 4K resolution for live viewing or local recording.

Issue 5:
They advertisers said that their use of the claim “unmatched 4k security” referred to the combination of features and innovations that they integrated alongside 4K resolution, rather than the resolution alone. While 4K technology may be available in the market, they said that the unique configuration of their solution, combining software and hardware qualities, differentiated it from competitors and justified the statement made in their campaign. They also said that 4K on a premium lens and sensor looked very different compared to 4K on another camera and depended amongst other things on lens quality, sensor size, image processing, optics and AI integration.

The advertisers submitted further information, stating that while 4k technology was available on the market, the quality of 4k delivery differed significantly. They said that they had conducted an internal comparative review of publicly available specifications such as resolution, HDR capability, colour night vision, field of view, dual motion sensors, AI detection range and cloud recording quality from major competitor products. They said that the analysis showed that while certain competitors now offered 4k resolution, they remained the only brand to combine true 4k resolution, HDR capability, full colour night vision and 4k cloud recording. They said that these features collectively differentiated their solution, which they believed substantiated their claim they their product was ‘unmatched’, was objectively supported and not presented in a manner likely to mislead consumers.

The advertisers provided a comparison table where they compared their product, the Arlo Ultra 2 against five other competitor products. Features included in the comparison were, video resolution, HDR support, colour night vision, dual motion sensors, cloud recording quality and AI detection range. The comparison showed that the advertiser’s product was the only product that combined all features.

Issue 6:
They advertiser said that the wording “10 Years of Perfecting” was intended to communicate their ongoing efforts at innovation and enhancement of their offerings, not to suggest that their brand or products had reached perfection. They said that the progressive form “perfecting” emphasised a continuous process rather than a completed achievement.

The Complaints Council considered the detail of the complaint and the advertisers’ response.

Issue 1 – Not Upheld:
The Council noted that a temporary technical error had resulted in the discount code not working in some cases and that steps had been taken to rectify the error once identified. The Council also noted that all qualifying customers had received the discount. In the light of the fact that the error was a temporary technical error that was rectified, and the discount code provided in the advertisement was correct, the Council did not consider that the advertising was in breach of the Code.

Issue 2 – Not Upheld:
The Council noted that the claim made in the advertisement was “10 years of perfecting home security” and that the basis of the complaint was that the reference to ‘home security’ implied that the product being offered for sale was a home security system. The Council noted that the advertisement had not made any reference to ‘system’, and that the advertisement had referenced what was being offered for sale. In the circumstances, the Council did not consider that the advertising was in breach of the Code on the grounds raised.

Issue 3 – Not Upheld:
The Council noted that the basis of complaint was that the claim (10 years of perfecting home security) was being made in regard to the products advertised, whereas the intention of the advertisement was that the claim was in relation to the brand. The Council considered the impression created by the claim, including its position within the advertisement and noted that the claim had been positioned on the bottom left-hand side of the advertisement. The Council also noted the examples provided to the Executive of the claim being used in other advertising campaigns. On balance, the Council did not consider that the impression created by the claim was that it was being made in regard to the products being advertised, rather they accepted that it was being made in regard to the brand. In the circumstances, the Council did not consider that the advertising was in breach of the Code on the grounds raised.

Issue 4 – Not Upheld:
The Council noted that no claim had been made in the advertisement in regard to recordings, however, they also noted that the camera advertised provided both live streaming and local storage in 4K resolution. In the circumstances the Council did not consider that the claim was in breach of the Code on the grounds raised.

Issue 5 – Upheld:
The Council noted that the claim made was ‘unmatched 4K security’ and that the intention behind the claim was in relation to the features and innovations that were integrated alongside the 4K resolution in comparison to other competitors on the market. The Council noted that the Code permitted comparisons and that advertisements that do not identify a specific competitor could still be considered to contain an implicit comparative claim as the comparison could be made with all competition within an industry. In this case, the Council considered that the claim was an implicit comparative claim. The Council also noted the requirements of the Code that a claim that any product is superior to others should only be made where there is clear evidence to support the claim and that such claims should be capable of substantiation. The Council noted the additional information provided, including the comparative review against five competitor products. The Council considered that no confirming evidence had been provided that the features selected were the only relevant 4k features of each product and also that no confirmation had been received that the competitors chosen were the only competitors in the market. In the circumstances and given the requirement in the Code that absolute claims should be capable of evidence by market share data or similar, the Council considered that the advertisement was in breach of Sections 4.1, 4.4, 4.9, 4.10 and 4.33 of the Code.

Issue 6 – Not Upheld:
The Council noted that the basis of complaint was that the claim to be ‘perfecting’ home security for 10 years had implied that the system advertised was ‘faultless’ and given that the complainant had experienced issues with their system, they considered the claim misleading. The Council noted that the claim made was ‘perfecting’ and that it had not been intended to be interpreted that their brand or products had reached perfection. The Council, while appreciating that the complainant had stated they had experienced issues, did not consider that the claim made was that the products or brand were ‘perfect’, nor did they consider a individual specific technical issue with a product negated an advertising claim. In the circumstances, the Council did not consider that the advertising was in breach of the Code on the grounds raised.

Action Required:
The advertising should not include the claim ‘unmatched 4K security’ without evidence to support the claim.