As you probably know Facebook recently revised its promotion guidelines to make it easier for brands to run very simple promotions. The main development is that you do not need 3rd party apps to administer a simple contest or sweepstakes on Facebook. You can now leverage the Facebook platform for entry collection and winner communications. For example, you can allow your customers to “like” your page or post a comment to gain an entry. Although this makes it easier to setup a promotion, it may present difficulties when administering the promotion, including entry collection, fraud mitigation, winner selection and winner verification.
The changes did not eliminate the requirement to include specific legal disclaimers regarding Facebook, and the promotion guidelines still provide that you are responsible for ensuring your promotion complies with all applicable laws, rules and regulations. Not only do you need legal and administration services for compliance purposes but also to preserve the fairness and integrity of your promotion. Our recommendation is that you should leverage 3rd party services like PrizeLogic to manage a promotion’s administration no matter the execution. You don’t want to get caught up in dealing with disgruntled losers. Full indemnification from harm is always best practice.
It is also important to remember that unfortunately a Facebook page cannot be used to obtain an opt-in for future marketing materials the way that an app can be used to collect valid affirmative consent to receive such communications. Thus, if building a database is one of your core objectives, or if you want to customize and optimize a promotion flow to match your brand objectives we suggest you still use an app.
If this was easy, we wouldn’t be in business…Thank You.
This summary is intended for general informational purposes only and is not legal advice.