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I don't generally tend to get bogged down with these ASA complaints because a lot of the time I think it's just compers being selfish / jealous (for the most part, I hate compers! ) but this one does seem a bit iffy ... the prize was a car so chances are there was probably 10s of thousands of entries( ? ) ... what are the chances they "randonly" chose a relative of an employee
"the winner was married to the cousin of an employee’s spouse"
I think that is distant enough not to break the "family" clause.
Even assuming the cousin is a first cousin, that's six degrees of separation on a family tree (Employee -> Spouse -> Spouse's Parents -> Spouse's Grandparents -> Spouse's Aunt or Uncle -> Spouse's Cousin -> Spouse's Cousin's Spouse). With the promoter having 580 employees there could easily be 10,000 people who are relatives as close as, or closer than this!
Interestingly, my workplace ran a competition, I wasn't involved with the draw but out of thousands of entries, the winner happened to be my ex boyfriend...so I guess it CAN happen!