Facebook Changes Approval Requirement

Facebook announced on December 1, 2010, significant revisions to its Promotions Guidelines that may potentially expand the ability of advertisers to utilize this important marketing channel to conduct promotions. While there are still critical restrictions on the use of the Facebook platform, under the new Guidelines, companies no longer need written permission from Facebook before administering a promotion on the Facebook platform.

Under the new Guidelines, a promotion cannot be administered through Facebook, except through an application on the Facebook Platform. Administration is broadly defined and includes the operation of any element of the promotion, such as collecting entries, conducting a drawing, judging entries, or notifying winners.

The Facebook Promotions Guidelines can be found here and are summarized below.

Sweepstakes and Contest Promotions Administered on the Facebook Platform

The following requirements apply to any sweepstakes or contest promotion administered through an application on the Facebook Platform:

  1. The promotion can only allow user to enter in the following locations: a) on the canvas page of the application; or b) on the application box in a tab on a Facebook page.
  2. The following disclosure must be made: 1) Adjacent to any promotion entry field: "This promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook. You are providing your information to [disclose recipient(s) of information] and not to Facebook. The information you provide will only be used for [disclose any way that you plan to use the user's information]." and 2) In the promotion's rules: a) a complete release of Facebook by each entrant or participant; and b) acknowledgement that the promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook.

General Restrictions

The following restrictions apply to any promotion communicated on Facebook or administered through an application on the Facebook platform. Communication includes promoting, advertising or referencing a promotion in any way on Facebook, for example, in ads, on a page, or in a status update.

You may require that an entrant like a page, check-in to a place, or connect to your platform integration before providing their full entry information for a promotion. You will not condition entry to the promotion upon taking any other action on Facebook, for example, liking a status update or photo, commenting on a Wall, or uploading a photo. You cannot directly or indirectly indicate that Facebook is a sponsor or administrator of, or in any way associated with, the promotion. You cannot use Facebook's name, trademarks, trade names, copyrights, or any other intellectual property or mention Facebook in the rules or materials relating to the promotion, except as set forth below. To disclose the requirement of liking a page, checking in to a place, or connecting with platform integration. If you administer the promotion through an application on the Facebook platform, you may mention Facebook in the following ways: "You can enter the promotion through the [application name] application on the Facebook platform. You can also find the application on the [tab name] tab on the [page name] page on Facebook."

Some requirements from the prior Facebook promotion guidelines remain the same. Such as, you may not communicate about or administer a promotion on Facebook if:

  1. The promotion is open or marketed to individuals who are under the age of 18;
  2. The promotion is open to individuals who reside in a country embargoed by the United States;
  3. The promotion, if a sweepstakes, is open to individuals residing in Belgium, Norway, Sweden, or India;
  4. The promotion's objective is to promote any of the following product categories: gambling, tobacco, firearms, prescription drugs, or gasoline;
  5. The prize or any part of the prize includes alcohol, tobacco, diary, firearms, or prescription drugs; or
  6. The promotion is a sweepstakes that conditions entry upon the purchase of a product, completion of a lengthy task, or other form of consideration.

Other Restrictions and Examples

You cannot: Condition entry in the promotion upon a user providing content on Facebook, such as posting on a Wall of a page, uploading a photo, or posting a status update.

You can: Use a third-party application to condition entry to the promotion upon a user providing content to the application. For example, you may administer a photo contest whereby a user uploads a photo to a third-party application to enter the contest.

You cannot: Administer a promotion that users automatically enter by liking your page, checking in to your place or connecting to your platform integration.

You can: Require entrants to like your page, check in to your place or connect to your platform integration before they provide their full entry information, such as name and contact information.

You cannot: Notify winners through Facebook, such as through Facebook messages, chat, or posts on profiles or pages.

You can: Collect an email or address through the third-party application for the promotion in order to contact the winner by email or standard mail.

You cannot: Instruct people (in the rules or elsewhere) to sign up for a Facebook account before they enter the promotion.

You can: Instruct users to visit the third-party application to enter the promotion. Since users must have a Facebook account in order to access an application on the Facebook Platform, if you give this instruction, they will be prompted to sign up for a Facebook account if they do not already have one.

Important Tip: Because advance consent from Facebook is no longer required, the revised guidelines will make it easier to run promotions on the Facebook platform. Keep in mind however that the promotion must comply with these and other Facebook requirements as well as the laws governing sweepstakes and contest promotions. Before starting any promotion, it is important to review the promotion's structure and draft a set official rules specific to the promotion.

For assistance on your next promotion or to learn more about our Sweepstakes, Promotion, and Social Media Law practice, click here.

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