Why every spin wins — compliance behind the wheel

The legal reasons we enforce at least one winning prize per slice and block the old no-prize configurations.

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, and color per 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.