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I'm looking to run a giveaway competition on my website. The main aim of the competition is to get signups to our email newsletter. I'm therefore proposing that 1. a user signs up to my newsletter (with the usual caveats, opt-ins etc), then 2. once they are signed up they will be shown a separate, standalone option to enter the competition.

This would allow people already signed up to still access the competition entry as our system would know their email address is signed up with us.

I think I'm safe in that competition entry is not bundled with the newsletter signup, they are separate actions, but the competition is only open to those that are signed up to the newsletter. Is that GDPR compliant?

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As so often here, my advice is "get a specialist lawyer in your jurisdiction." That being said, GDPR requires free and informed consent to data handling. The concept you should be looking at is informally called coupling, formally defined in Article 7(4), and it is broadly speaking forbidden -- you may not make features conditional on consent if the consent is not required for the feature.

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  • The word "coupling" occurs in your link once: "By coupling information from registries, researchers can obtain new knowledge of great value with regard to widespread medical conditions such as cardiovascular disease, cancer and depression." Is that what you meant? What the OP is suggesting sounds to me like what every GDPR popup asks for, consent to have you PII processed for advertising purposes in exchange for access to information, so I would be interested in how this could be forbidden.
    – Dave
    Apr 30, 2021 at 8:35
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    @Dave, the term coupling is the colloquial term for what Art. 7(4) describes. Googling "GDPR coupling" or "GDPR coupling prohibition" provides lots of relevant hits. I edited to clarify informal and formal usage.
    – o.m.
    Apr 30, 2021 at 10:17

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