> These terms are interpreted and are subject to the jurisdiction and the laws of Poland
Which is really intriguing, since organizing any form of lottery or chance-based game is so complicated, that virtually nobody who knows anything about the subject would dare to try.
When I worked in advertising nobody in their right mind would create a promotional campaign with prizes given away to randomly picked winners, there had to be objective criteria (skill, talent, popular vote etc). E.g. when we made a memo-like browser game, the lawyers said we need to show all the cards for a few seconds, so there's an element of skill (memorization of the board) instead of chance (the cards being randomly distributed). And if my memory serves, finishing the game was required to enter the contest, but to win the prize there was an extra text field where participants had to answer something like "why would you like to win the prize?", and the best answer, picked by a jury, was awarded.
There were people playing poker with family and friends raided by police. (I think poker is now considered at leat partially skill based and some laws were fixed since).
There were teachers going trough hell when trying to make a simple lottery as a part of school fund raiser event.
If they really operate in / from Poland, it may not take long for this to get shut down if the authorities get involved.
Edit: found a detailed overview of the regulations in English here: https://uk.practicallaw.thomsonreuters.com/8-635-6028?transi...