Pinterest®, since it first appeared on the scene in 2010, has been the darling of crafty do-it-yourselfers (DIYs), ambitious brides-to-be, fitness aficionados, Pinterest has consistently presented itself as a tool that could be used by consumers for a natural, authentic experience, giving users full artistic and creative reign as they pinned images and designed boards.
The Federal Trade Commission recently issued a closing letter to high-end shoe retailer Cole Haan that has implications for broadcasters conducting contests on social media platforms like Twitter and Pinterest.
In a recent (March 20, 2014) letter, the Federal Trade Commission (FTC) offered guidance as to the factors to consider in evaluating whether entry into a contest on a social media site is a form of material connection requiring disclosure under the FTC Endorsement Guidelines.
The FTC “Pins” Cole Haan On Pinterest Campaign: Disclosure of Contest Driving Endorsement of Products Required
The rise of social media for contests and marketing campaigns has captured the attention of the Federal Trade Commission (FTC), particularly campaigns that provide for contest entry based on what amounts to social media endorsements.
The Federal Trade Commission’s Division of Advertising Practices has recently finalized its investigation into a Cole Haan’s “Wandering Shoe” contest wherein contestants could enter the contest by creating Pinterest boards titled “Wandering Sole” and including five shoe images from Cole Haan’s Wander Sole Pinterest Board as well as five images of contestants’ “favorite places to wander.”
#SMH-butnotacontestorsweepstakes – Check Your Online Promotion Hashtag or Face Scrutiny from the FTC
As we have reported before, the Federal Trade Commission requires the disclosure of any “material connection” offered in exchange for an online endorsement or post in their Online Endorsement Guidelines.
#Sweepstakes and #Contest #Entries On Pinterest Are Endorsements, Says FTC; Implications Beyond Pinterest
The Federal Trade Commission (“FTC”) recently investigated Cole Haan, Inc. to determine whether a contest that it conducted on https://www.pinterest.com violated Section 5 of the FTC Act, which, in part, requires the disclosure of a material connection between a marketer and an endorser when their relationship is not otherwise apparent from the context of the endorsement.
FTC Says That Sponsors of Pinterest Contests Should Require Users to Post Pins with Hashtags Warning When Pins Are Posted for a Prize
In a March 20, 2014 closing letter sent to fashion company Cole Haan, the FTC warned that use of the hashtag #WanderingSole in conjunction with a recent Pinterest contest did not adequately communicate the “material connection” between Pinterest contestants and Cole Haan and violates Section 5 of the FTC Act.