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I don't think there is any problem with that (but I'm not a lawyer).
I would be concerned (for you) that the promotion was designed so that (a) one person didn't snag all 50 first-come positions and (b) that it was painfully clear that the $100 is the END of it, there is to be no expectation of additional benefits ... and that anything having to do with taxes and so on are the exclusive responsibility of the receiver.
Keep contact information for each of the "winners", and absolutely run the promotion's content by a barrister before you open it to the public. You may be able to categorize your promotional expense as a tax benefit for your company.
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