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In marketing to younger consumers, contests and sweepstakes can be effective tools for increasing brand engagement. Although these types of promotions are similar, there are differences between sweepstakes and contests.
In general, a sweepstakes gives a child the opportunity to “build on luck”, such as winning a prize through a random draw, while a competition is more challenging, where a prize is awarded after a demonstration of skill, such as a drawing competition based on a set of judging criteria.
On the surface, these types of promotions may seem simple, but a company can quickly find itself in trouble if its contest or sweepstakes is aimed at or may reach children under the age of 13.
Through its pre-screening services, the Children’s Advertising Review Unit (CARU) has seen first-hand how well-intentioned companies can make common mistakes when running competitions or sweepstakes. For example, the risks of collecting too much personally identifiable information (PII), collecting certain information without first obtaining verified parental consent (VPC), and potentially violating the Children’s Online Privacy Protection Act (COPPA) are common pitfalls for both types of promotions. .
So how do you avoid falling into these pitfalls when designing and planning an online sweepstakes or contest? Here are some things to keep in mind.
Think about your target audience and how you will collect offers and award prizes.
If your online sweepstakes or contests are aimed at children under the age of 13 or at a “mixed child-targeted audience” (where the online service is targeted at children but not aimed at children as the primary audience), be aware that you will have to comply with CARU’s Advertising and Privacy Policy and COPPA.
COPPA applies to the online collection of personal information from children under the age of 13. Personal information may include any of the following: full name, email address, address, telephone numbers, photographs, videos, audio recordings, persistent tracking identifiers, and precise geolocation data. If your participants are under 13 and you need to collect personal information as part of the contest or sweepstakes entry process, make sure you understand whether COPPA requires you to obtain a VPC.
For example, if you want to receive any information from children other than basic online contact information (name and email address only), such as receiving a winner’s home address to send a prize, you must first notify the parent directly and get a VPC. Direct Notification is a process in which parents are directly notified in clear and easy-to-read language about your disclosure practices prior to receiving information from their child.
Under COPPA’s “single-use” exception, you may obtain a child’s email address without first obtaining a VPC, as long as the data collection is not combined with any other personal information, such as a full name or mailing address. While the contest is ongoing, you must protect or hash the information, and then you can contact your child once after the contest to let them know they won or lost. You must delete this child’s information after the promotion ends.
If your online sweepstakes or contest is aimed at children under the age of 13 or at a “mixed audience aimed at children”, consider your request to entrants.
Is this a contest where contestants will create user-generated content (UGC) as part of their work? If your contest requires children under the age of 13 to provide UGC, such as a photo or video, consider whether you can design the contest so that participants do not have to provide any personal information, such as their full name, address, or a picture of themselves, and they are expressly told not to send such identifying information. If a submission contains a photo or image of a child, this is considered personally identifiable information under COPPA and you will need to obtain a VPC before collecting such information.
Make sure your audience under 13 knows that the contest or sweepstakes is an advertisement.
If your primary or secondary audience is children under the age of 13, remember to design the contest with a child audience in mind. For example, in terms of design and user interaction, is it clear to children that an ad is an ad? Does your contest promotional content clearly and prominently state, in language that is easy for children to understand, that your sweepstakes or contest is or contains advertising? Is there inappropriate language, such as legalese, in the ad?
This mock ad contains a fictitious brand disclosing that the promotion is an ad for illustration purposes only.
Consider audience segmentation.
If you advertise to mixed audiences that target children under 13, but do not target children under 13 as your primary audience, under the Children’s Online Privacy Protection Act (COPPA), you have the right to verify age to ensure protection of children under the age of 13, but not to exclude them. If you screen members by age, you can segment your audience and provide COPPA protection for children under 13 by creating a different experience for non-COPPA members, allowing children of all ages to participate and interact with your brand.
For example, if your contest requires entrants to submit UGC and you want to encourage them to share their creations on social media, exclude that element from your 13-and-under promotion. In accordance with COPPA, the sharing and collection of personal information without a VPC is prohibited.
This mock ad features a fictitious brand performing an age screen for illustration purposes only.
Here are some common mistakes to avoid when promoting.
In our routine monitoring of advertising and marketing aimed at children, CARU often finds errors at various stages of the sweepstakes and contest process, such as the registration process, flags and age windows, etc.
- Collection of too much personal information during the entry stage of the promotion. Need to collect more than a child’s name and email address to complete your promotion? To limit your company’s compliance with COPPA, consider data minimization and collect only the information you need to serve your ad.
- Poorly executed age gate. If you apply an age restriction to your promotion, it should be age neutral. An age-neutral screen is an age screen that asks a child for their date of birth or age without prompting, telling participants that they must be at least 13 years old to participate, suggesting that their experience with the promotion or the prizes awarded will be different , if they state that they are under the age of 13 or use any other mechanism that may induce a participant under the age of 13 to misrepresent their age in order to participate. In addition, where age restrictions exist, accessible technologies should be used so that children cannot use the back button to change their age after receiving a notification, for example, that they are not eligible to participate or do not meet the minimum age requirements. age
- Use of legal language for a children’s audience. A child may not fully understand the content of the Privacy Policy and Terms of Use, which contain complex language. Use clear and simple language so children can understand what they are reading. And because children, as minors, cannot legally consent to these contracts, CARU encourages you to consider the usefulness of asking children to agree to your Privacy Policy and Terms of Use.
- “Consent” offer for marketing email flags. COPPA prohibits children under the age of 13 from receiving marketing or promotional materials without first obtaining a VPC. While it may be common practice to use this option to opt-in to marketing materials from those 13 years of age and older, flags or other language that asks children under 13 to consent to receiving this type of information, without a VPC, is a violation of COPPA.
We collect everything together
There are many things to consider when organizing contests and sweepstakes for children or mixed audiences for children. At every step, it is important to take into account the special vulnerability of children, implementing the true principles of advertising and privacy by design. It’s also important to consider the platform you’re using and make sure you follow its specific sweepstakes and contest rules and guidelines.
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