If this is viewed as a gambling scheme then maybe I should have called it a raffle instead?
I think it's better to call it a raffle than giveaway.
People purchase the spooky nft as the product but the product just happens to have a raffle ticket as a side perk. But if people's reasons to purchase the nft was to make it a means to join a raffle, then that is gambling for me. It's really the intentions behind purchasing the nft in the first place. I could buy the nft without knowing or even participating in the raffle and I'm not even gambling at all. But if someone else purchased the nft for the sake of getting a raffle ticket, then that's where the gambling comes in. A difference of intention but same execution.