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Question regarding gifting gem items

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I wanted to see if this was allowed / not against any EULA/ToS/etc. for the game before I did anything. If I wanted to hold a small raffle on my guild website (using money leftover from donations by various members to help cover website and voice server costs), and select one winner to receive a gifted item from the gem store, would that be allowed?

I know we are allowed to gift items to other players as long as it has the gift button available for said item, just not sure if a raffle would be permitted to see who in my guild would win an item. Please note that if it is allowed, I'd be setting up my guild website donation with a disclaimer stating exactly what the donations are used for, including any money left over at the end of the month, so there would be no surprises.

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