Sweepstakes & Contests

1. Purpose

This SOP establishes the standard process for running any promotion, newsletter giveaways, social contests, partner prize drops, in-app rewards. The goal: drive growth without creating legal exposure. Marketing terminology is loose; the legal categories are precise. Misclassifying a promotion is the most common way companies accidentally run an illegal lottery.

2. The three legal categories

Every promotion is defined by three elements: Prize, Chance, and Consideration.

Key terms. Prize: anything of value awarded. Chance: winner selected randomly. Skill: winner selected on objective or judged criteria. Consideration: anything of value the entrant gives up, money, substantial time/effort, significant personal data, or in some states social engagement.

3. "Giveaway" is not a legal category

Every "giveaway" is legally either a sweepstakes or a contest. Use the precise term in any official rules, sponsor agreement, or legal-facing document. "Giveaway" is fine for marketing copy, never in legal docs.

4. Required elements of a compliant sweepstakes

4.1 Official Rules (on a dedicated landing page)

Must contain: eligibility (18+, US residency, employee/family exclusions, void where prohibited); entry period with time zone; how to enter; a free Alternative Method of Entry (AMOE) with equal chance of winning; prize description with ARV; odds of winning; winner selection method and date; notification process; sponsor of record (legal entity and address); "NO PURCHASE NECESSARY. VOID WHERE PROHIBITED."; tax responsibility; publicity rights; privacy disclosure; and governing law.

4.2 Entry surface disclosures

"NO PURCHASE NECESSARY" must appear on the entry surface itself (newsletter, landing page, social post), not buried only in the rules.

4.3 Sponsor agreement (if a third party is involved)

Required whenever a third party provides the prize, funding, or co-branding. Must specify sponsor of record, administrator, prize fulfillment obligations, indemnification (both directions), marketing rights and approvals, and data sharing terms.

4.4 Privacy disclosure at entry

Link the privacy policy at the entry point. If entrant data will be shared with the sponsor, disclose it explicitly at the point of entry, not just in the rules.

5. State registration thresholds

Standard practice for pools over $5,000: register in NY and FL, exclude RI from retail-tied promotions, exclude Quebec, always include "Void where prohibited."

6. When to loop in Legal

Notify Operations before launch if: prize value over $1,000; any consideration beyond newsletter signup or basic contact info; skill contest with subjective judging; co-branded promotions with a third-party sponsor (always); promotions accessible to minors; international entrants; anything tied to alcohol, gambling, or regulated industries; influencer or affiliate involvement (FTC disclosure); social share-to-enter mechanics; or anything that doesn't fit an approved template. For routine, low-value, US-only newsletter sweepstakes, legal reviews the template once, then Growth can reuse it provided no facts change.

7. What to avoid

• Running a random-winner promotion with purchase, social shares, or significant data collection without an AMOE
• Using "giveaway" in legal documents
• Posting only T&Cs and skipping Official Rules
• Launching a sponsored promotion without a written sponsor agreement
• Sharing entrant data with a sponsor without explicit at-entry disclosure
• Letting prize fulfillment ride on a verbal sponsor commitment
• Running prize pools over $5,000 without state registration
• Including minors without a parental consent flow
• Subjective judging in a contest without published criteria

Process

Step 1, Intake (Marketing): complete the Promotion Intake with name, type, prize and ARV, entry mechanic, entry period, sponsor, channels, and audience.
Step 2, Classification & approval (Operations): classify the promotion, confirm registration triggers, sponsor agreement need, and approved rules template.
Step 3, Documentation: finalize Official Rules and, if applicable, the Sponsor Agreement. Sponsor must confirm prize funding in writing before launch.
Step 4, Build: landing page with rules link, "NO PURCHASE NECESSARY," sponsor and privacy disclosures, AMOE instructions; creative includes required disclosures; entry form captures only what's necessary.
Step 5, Launch & monitor: track entries with timestamps; preserve records at least 12 months.
Step 6, Winner selection: documented random drawing, notify per rules, prize delivered by sponsor or Plei.
Step 7, Close-out: archive rules, entries, drawing record, sponsor agreement, and delivery confirmation in Drive; brief retro.