As you may know, Facebook recently changed its Promotion Guidelines. Businesses now have more flexibility for running sweepstakes, contests and other promotions on its platform. Click here to watch a short video prepared by Facebook describing the changes.

What are the changes?

Facebook removed the requirement that all promotions on Facebook must be administered within apps. Under the new guidelines promotions may now be administered on page timelines using native Facebook functionality and also through apps.

What we can now do:

• Collect entries by asking users to like or comment on a page timeline post;
• Collect entries by asking users to send a message to a page timeline post;
• Use likes (and the like button plugin) on Facebook pages, apps or websites as a voting mechanism;
• Notify and announce winners on page timelines and Facebook messages.

What we cannot do:

• Cannot collect entries by asking users to like, share or post on personal timelines or their friends personal timelines;
• Cannot use tags as an entry mechanism if the user tagging does not appear in the photo being tagged.

What has not changed?

• Promotion sponsors are solely responsible for the lawful operation of a promotion on Facebook, including:
  • The official rules, offer terms and eligibility requirements;
  • Compliance with regulations governing the promotion including registrations and obtaining necessary regulatory approvals;
  • And all prizes offered in connection with the promotion.
• In addition, all promotions on Facebook must include:
  • A complete release of Facebook by each entrant or participant;
  • Acknowledgement that the promotion is in no way sponsored, endorsed, administered by, or associated with Facebook.
• Sponsors may still run promotions through apps, which enable sponsors to create a more personalized experience and collect user data in a more secure, structured manner.

Considerations when choosing apps or Facebook functionality for promotions:

Using Facebook functionality as entry mechanism:

• Quick and easy to launch promotions on Facebook;
• Encourages immediate interactions/conversations between participants and sponsor;
• Allows users to view all related posts, comments and likes which may generate more active engagement and promote viral activity;
• Sponsors need to convey and enforce legal rules, terms & conditions and eligibility requirements;
• The process to collect entry data, select and validate winners may be less efficient with more manual steps than when using an app.

Using Apps as entry mechanism:

• Apps offer more opportunity to showcase the brand and provide a placeholder to describe the promotion in greater detail;
• Apps provide a placeholder to disclose required legal rules, terms & conditions and privacy policies;
• Apps offer a structured and secure process to administer the promotion to collect and validate participant data, ensure legal compliance and minimize risk for the brand;
• Apps can efficiently interface with operation platforms for winner selection, notification, eligibility validation and prize/ offer fulfillment;
• Apps offer the opportunity to request additional input from participants through polls, surveys, and opt-in for future communications/ offers.

How Arrowhead can help:

• Whether you choose to use an app or Facebook functionality we can help ensure your promotion is legal and Facebook compliant, minimize risk and ensure the program operates according to plan including:
  • Support promotion strategy, provide advice, oversight and risk assessment;
  • Develop legal rules and manage any required government registrations and approvals;
  • Technology support to develop and launch apps to showcase the promotion;
  • Extract, collect and validate participant data in secure and structured environment;
  • Determine winners to comply with rules, notify and validate winners, execute as needed affidavits, liability releases and any required IRS reporting;
  • Procure and fulfill prizes;
  • Manage promotion timetables and troubleshoot throughout the process.

We hope this information is helpful. Please let us know if we can answer questions or help with any of your upcoming promotions.

Kind regards,

Robert Borman
VP, Sweeps & Games
Arrowhead Promotion & Fulfillment Co.
O 218.327.8680 ext 565 / M 763.286.0029
robertb@apfco.com
www.linkedin.com/pub/robert-borman/5/53/210/