So are you then claiming that the mere raffle-like mechanics in and of themselves are a violation of gambling laws or… what?
Despite you talking about legal definitions this, the law as it stands that, you still have no actually provided the definition. Why can’t you do this?
There’s one hereinabove squire, that gives a high-level legal overview. You can also start your journey here: Gambling Act 2005
The rest I leave up to you, but I would encourage you to read the full Select Committee minutes if you are that interested. I’m not going to do all of your homework for you, so I’ll leave your digits to fondle the keyboard on your favourite search engine.