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Is a wheel-spin game allowed?

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Question: 
We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.
Answer: 

I don’t see it as a lottery as everyone wins, although some will win more than others. I would put this in the contest category as a skill could be required to spin the wheel and win greater amounts. There is an element of skill and chance. There may be other concerns over the method of payment.

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Sweepstakes, Contests and Lotteries, Oh My!

First published on 08/16/2020

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