Every slice on the spin wheel must be a real prize with a coupon code. You can't create "Better luck next time" or "No prize here" slices. This is a product rule we enforce, and it exists because a spin wheel with losing outcomes — awarded in exchange for a testimonial — would put you on the wrong side of several sets of consumer-protection laws at once. This article explains which ones.
The short version
If a customer gives something of value (a testimonial) for a chance to win a prize, you're running an illegal lottery in several US states unless you remove one of those three elements. We remove "chance" by guaranteeing every spin produces a prize. The wheel varies the value of the prize, not whether the customer wins.
The three-element test (Prize + Chance + Consideration)
US state lottery law is mostly uniform on one point: a promotion that combines three elements is an illegal lottery.
- Prize — anything of value. A coupon counts.
- Chance — the outcome is randomized. A wheel counts.
- Consideration — the customer gives something of value to play. Several states interpret "substantial effort that benefits the sponsor commercially" as consideration — and a testimonial is exactly that kind of effort.
A normal retail sweepstakes solves this by dropping consideration (e.g. "No purchase necessary — mail in your entry for free"). A skill contest solves it by dropping chance (winners judged on merit). Our spin wheel solves it by dropping chance — every spin wins. Nobody loses, so the mechanic is no longer a lottery anywhere.
FTC Section 5, EU UCPD, and UK CAP Code
Three overlapping deception rules reinforce the same outcome:
- FTC Act § 5 (US) prohibits deceptive acts or practices in commerce.
- EU Unfair Commercial Practices Directive (2005/29/EC) prohibits creating a false impression of winning chances.
- UK CAP Code (non-broadcast) requires that all significant conditions of a prize promotion — including the real odds — be disclosed upfront and that the promoter not create a false impression that a consumer has or will win.
Showing a "no prize" slice a customer cannot land on, or drawing equal-sized wedges while rigging the probabilities behind them, is a textbook deceptive practice under all three regimes. By removing losing slices entirely and enforcing equal visual slices whose values differ, we stay clear.
FTC Consumer Reviews & Testimonials Rule (2024)
The FTC's 2024 rule is directly about what we do: collect consumer testimonials. Its relevant points:
- Offering an incentive for a testimonial is fine.
- The incentive must be disclosed.
- The incentive cannot be conditional on positive sentiment.
Our default disclosure copy reads: "This is an incentivized testimonial — rewards are given to anyone who submits, regardless of what they say." That copy is shipped with every spin-wheel form by default, on the Welcome step. The every-spin-wins rule backs this up: since the reward is guaranteed, there is no way for a customer to reasonably believe they'd get a better deal by writing a more positive testimonial.
See Incentivized testimonials — FTC disclosure done right for the full disclosure story.
What we enforce automatically
- No losing slices. The builder has no "Win / Lose" toggle. The save path normalizes any legacy losing slices out of the config before it hits the database.
- No 0% slices. Probabilities ≤ 0 are replaced with 1 (uniform) on save.
- Coupon code required on every slice. Save is blocked with a clear error if any slice is missing a code.
- At least two slices. Save is blocked below that threshold.
- Public payload sanitized. The browser receives only
id,label, andcolorper slice. Probabilities and coupon codes never reach the customer before the server has picked a winner. - Server-authoritative pick. The winning slice is chosen server-side and its index is returned — the browser cannot rig which slice it lands on.
- One spin per email per form, forever. See the Spin the Wheel article for how the explainer banner handles repeats.
What you, the operator, should still do
- Keep the disclosure on. The toggle lives in Reward tab → Reward Display → Include incentivized-testimonial disclosure. It's on by default; leave it on unless you have your own legal-reviewed disclosure elsewhere.
- Don't promise specific win probabilities in outbound marketing. Emails like "80% chance of 50% off!" create a promise we can't guarantee — the wheel picks weighted-random, not percentage-fixed.
- Don't word the prompt as a positivity bribe. Copy like "Leave a glowing review to claim your reward" violates the FTC Testimonial Rule, regardless of what our disclosure says.
- Respect the once-per-email guard. Don't try to work around it with scripts or reused email addresses — the guard exists to protect you from sweepstakes fraud, not just the customer.
Jurisdiction note
These rules travel with the customer, not with your business. A US resident completing your form triggers US state lottery law + the FTC Act no matter where your company is incorporated. Same logic for EU and UK visitors. "We're based in Singapore, so US law doesn't apply" is not a defense the FTC, Trading Standards, or a state AG will accept. The every-spin-wins design is compliant everywhere, so you don't need to geo-gate anything.
Not legal advice
This article is product guidance on why we designed the feature the way we did. It isn't legal advice. For large-scale promotions, campaigns that differ materially from the built-in reward flow, or any jurisdiction where you have specific concerns, talk to counsel who knows promotion law in the relevant markets.