Is it gambling if there is no money?
No, and the reason is in the statutes. Gambling law almost everywhere is built from three elements: a stake, an outcome that turns on chance, and a prize. Take away the stake and the definition is not met, so the licensing regime never engages. The UK, Germany, France, Spain, Italy and Brazil each write the money element into their own text, in their own words, and each one is quoted below.
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