My company run a popular monthly photo competition, we allow users to vote on the photos, with the top photo receiving a cash prize. We run the competition globally (essentially, all traffic is US, GB, CA and AU), but based in the UK.
We also have a virtual currency, gems, which can be used to buy bonus votes and unlock features on the site/app.
Gems are given away, as rewards for completing achievements, checking in daily, etc. We also sell the "gems" at one of five tiers.
We want to add some form of mini game (roulette probably), where we would give away the first spin away for free, then additional spins would be charged, gems and/or cash.
- Does this class as gambling? (I assume yes)
- Would it differ if we removed the cash prize?
- How do games, like 8 Ball Pool, get away with it (Spin & Win, Scratch)
Any advice on this would be greatly received.