Question: How can brands ask their consumers to invite their friends to participate in a promotion without breaking GDPR rules?

30 Apr 2021

We at VCG are often consulting on ideas which involve consumers signing up their friends to receive coupons, prizes or entries in a promotion. Immediately the challenges of data privacy and permissions arise. The consumer has no right to enter their friend's data and the brand has no right to process that data without the friend's permission.

The Mars Win2gether campaign, created by The Mars Agency and powered by VCG, is rooted in one key idea - that the winner wins a prize for themselves AND the same prize for their friend. www.win2getherpromo.com.

Our solution was to introduce a "send to my friend" button that brought up a pre-worded email with embedded unique claim link into the winner's own email account. All the winner needs to do is personalise that email and send it on. At this point, Mars has no knowledge of who the winner is sending the link to.

The friend clicks on the link to a claim page that allows them to review and accept ts and cs and privacy policy before claiming their prize. The data controller now has permission to process the friend's data.

A simple, effective and compliant solution that we are quite proud of.