Facebook Promotion/Contest changes on December 1st

[jerryk]

Facebook changed their rules on Promotions Contests/Sweepstakes on December 1st.
Here's the link to Facebook rules: Promotions Guidelines | Facebook

My question specifically, based on my first contest I recently ran, does having a link to my ContestBurner sweepstakes listed in my Facebook Fan page post, mean I have to administer the contest through the Facebook platform?

I have been talking with other marketing consultants who bought ContestBurner but have not used it yet, because they interpret Facebook rules as saying you cannot promote your contest at all on your Facebook Fan page.

Here is the exact two sentences they refer to from the Facebook rules;
"You will not administer a promotion through Facebook, except through an application on the Facebook Platform. Administration includes operation of any element of the promotion, such as collecting entries, conducting a drawing, judging entries, or notifying winners. "

The point that makes them cautious is the term "such as" because Facebook is not listing all the possibilities. They're concerned a link to the contest from the Facebook Fan page could be looked at by Facebook as an "element of the promotion" and thus the contest would have to be run on Facebook's platform and not ContestBurner.

Here are some of the other consultants concerns that we exchanged:
"Paragraph 1 still bothers me. Sounds like we cannot tell people to head over to our website to enter a contest. Which we'd have to do to use ContestBurner."

"If you stretch it, telling people to go to your website to enter the contest could be interpreted as 'collecting entries' or not. Plus the rule says 'such as collecting…" which means it is not a definitive list and leaves it a little open to interpretation.

I would just hate to get my client's Fanpage shut down. So I may try to get some clarification from Facebook."

"I'm a little on the cautious side also. Mainly because of the Facebook wordage. E.t. "administer a promotion through Facebook" the use of administer is left without definition and if you are a part of, in total or as person that has a portion of control or involvement directly connected to a promotion, even mentioning or linking to a promotion may be seen as administering. As [she] pointed out, the way they use "such as" may lead to an interpretation issue. It is used to exhibit some examples but does not limit the possibilities to only those given.

While it would be nice to see the replies from both Facebook and ContestBurner, the only one that counts is from Facebook.

I don't think there would be a problem from someone not directly connected to the promotion mentioning it on Facebook, including a contestant, as long as it was not a condition to enter the promotion as a contestant."

Their concern is that Facebook would make the ruling against them, and then shut down the Facebook Fan page.

And that would be really bad if they were running the contest for a business client.

So have you talked with Facebook specifically about links to the contest on Facebook Fan pages - and does that break their rules?

I was in compliance with all other Facebook rules - no way to enter the contest from the Facebook page, no requirement to "Like" the Facebook page to enter the contest - or any other Facebook activity was required.

I want to be able to offer Contest Marketing to my business clients, but now I too have this question on Facebook promotions.

Jerry